SPR

SOCIAL POLICY RESEARCH ASSOCIATES

1330 Broadway, Suite 1426, Oakland, CA 94612

Phone (510) 763-1499/Fax (510) 763-1599

www.spra.com

An Evaluation of the 

Individual Training Account/Eligible 

Training Provider Demonstration

Final Interim Report

August, 2001

Submitted to:

U.S. Department of Labor

Employment and Training Administration

200 Constitution Avenue, NW

Room N-5637

Washington, DC 20210

Prepared for the U.S. Department of Labor by Social Policy Research Associates

Under a subcontract from

Mathematica Policy Research, Inc.

Social Policy Research Associates

Ronald D’Amico, SPR Project Leader

Alexandria Martinez

Jeffrey Salzman

Robin Wagner

Under the direction of:

Mathematica Policy Research, Inc

Paul Decker, Project Director

DOL Contract No. N-7731-9-00-87-30
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CONTENTS

ABSTRACT

EXECUTIVE SUMMARY..........................................................................................ES-1

I. INTRODUCTION ......................................................................................................I-1

INDIVIDUAL TRAINING ACCOUNTS IN THE CONTEXT OF WIA ..................................I-1

Services Available to Adults and Dislocated Workers..................................I-2

Role of Individual Training Accounts and Training Providers.....................I-4

CONCEPTUAL MODEL FOR THE EVALUATION...........................................................I-6

System-Level Model of ITA Implementation ...............................................I-7

Customer-Level Model of Training.............................................................I-11

GRANTEES SELECTED FOR THE DEMONSTRATION ..................................................I-13

RESEARCH DESIGN AND DATA COLLECTION..........................................................I-15

II. GRANT PLANS AND IMPLEMENTATION PROGRESS ....................................II-1

THE GRANTEES’ PRIOR EXPERIENCE AND READINESS ............................................II-1

Prior Experience with Using Vouchers ........................................................II-1

Overall WIA Readiness................................................................................II-4

GRANT PLANS AND GRANT IMPLEMENTATION........................................................II-6

SUMMARY.............................................................................................................II-10

III. CUSTOMERS’ USE OF THE ITA........................................................................ III-1

EMPHASIS ON TRAINING AND ITAS ....................................................................... III-1

Emphasis on Training in General............................................................... III-2

ITA versus non-ITA Training..................................................................... III-5

ESTABLISHING CUSTOMER ACCESS TO ITAS......................................................... III-5

Customer Flow through Core Services....................................................... III-6

Customer Flow through Intensive Services................................................ III-9

Movement from Intensive Services to Training and ITA......................... III-11

CHOOSING TRAINING OCCUPATIONS AND VENDORS........................................... III-11

Types of Customer Choice ....................................................................... III-12

Process Used in Making Choices............................................................. III-14

Staff Training and Organization to Support Decision-Making ................ III-16

LIMITS ON CUSTOMER CHOICE THROUGH LOCAL POLICIES................................. III-17

SERVICES PROVIDED TO TRAINEES DURING AND AFTER TRAINING...................... III-21

Services during Training........................................................................... III-21

Placement Services................................................................................... III-22

COORDINATING THE ITA WITH OTHER SERVICES ............................................... III-24

SUMMARY........................................................................................................... III-26
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IV. DEVELOPING THE ELIGIBLE TRAINING PROVIDER LIST 

AND CONSUMER REPORT SYSTEM.................................................................IV-1

DESIGN OF INFORMATION SYSTEMS......................................................................IV-2

Vision of the Eligible Training Provider List .............................................IV-2

Disseminating Information about Vendors.................................................IV-5

INITIAL ELIGIBILITY APPLICATION PROCEDURES AND REQUIREMENTS.................IV-7

Marketing Efforts by States and Local Areas.............................................IV-7

Submitting an Application for Eligibility...................................................IV-8

Information Required for Application......................................................IV-10

Developing Regional Approval Systems..................................................IV-12

SUBSEQUENT ELIGIBILITY APPLICATIONS AND PROCEDURES..............................IV-13

PERFORMANCE MEASURES ..................................................................................IV-14

Performance Criteria for Initial Eligibility...............................................IV-14

Performance Criteria for Subsequent Eligibility......................................IV-15

Defining Key Terms .................................................................................IV-17

Data Collection.........................................................................................IV-19

PAYMENT SYSTEMS.............................................................................................IV-20

SUMMARY...........................................................................................................IV-21

V. TRAINING VENDORS: INVOLVEMENT AND PERSPECTIVES .................... V-1

TYPES AND NUMBERS OF VENDORS ....................................................................... V-1

VENDORS AND CUSTOMERS.................................................................................... V-3

Vendor Responsiveness to Customers......................................................... V-3

Recruiting Customers .................................................................................. V-5

VENDORS’ RESPONSES TO THE ITA SYSTEM.......................................................... V-6

RESHAPING THE TRAINING MARKETPLACE FROM JTPA......................................... V-8

Structure of the Market................................................................................ V-8

Tuition Costs.............................................................................................. V-10

SUMMARY............................................................................................................ V-11

VI. SUMMARY AND PRELIMINARY OBSERVATIONS......................................VI-1

CONTEXT...............................................................................................................VI-1

CUSTOMERS’ USE OF ITAS....................................................................................VI-2

DEVELOPING THE ETP LIST AND CONSUMER REPORT SYSTEM.............................VI-6

VENDORS’ REACTION............................................................................................VI-9

PRELIMINARY CONCLUSIONS ..............................................................................VI-10
ABSTRACT

The Workforce Investment Act of 1998 requires that, with certain exceptions, 

training services be delivered through the use of Individual Training Accounts (ITAs), 

which participants can use to procure the training of their choice, so long as the training 

program is on a state’s eligible training provider (ETP) list. In March 2000, the U.S. 

Department of Labor made grant awards to thirteen states and local areas as part of the 

ITA/ETP Demonstration, to provide support for ITA and ETP system development and 

encourage innovative approaches and practices. This paper presents interim findings 

from the evaluation of these grantees’ efforts. As such, it describes at about the midpoint 

of the grants’ period of performance what ITA policies and practices were being 

formulated, how ETP lists were being assembled, and what information was available in 

the consumer report systems, a repository of information about eligible programs that 

customers can use to make their training choices.
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ES-1

EXECUTIVE SUMMARY

This report has been prepared as part of a contract awarded by the U.S. Department 

of Labor (DOL) to conduct an Evaluation of the Individual Training Account/Eligible 

(ITA/ETP) Training Provider Demonstration. This summary reflects the findings 

reported in the Interim Report for the evaluation; as such, it describes early progress 

made by the demonstration grantees in establishing their ITA/ETP systems, based on site 

visits we made to each of them during the summer and fall of 2000.

BACKGROUND

The Workforce Investment Act (WIA) of 1998 brought about substantial changes 

in services provided to persons seeking employment and training assistance. An 

important element of WIA is the requirement that training services be provided, with 

certain limited exceptions, through individual training accounts (ITAs), which can be 

thought of as a voucher that customers can use to pay for training of their choice, so long 

as the training program is on an approved list (the eligible training provider list) and 

meets minimum standards of performance. To help customers make prudent training 

choices, information about the eligible programs approved by the state (e.g., costs of the 

training, its duration, and the employment and other outcomes achieved by prior cohorts 

of trainees, among other things) is to be assembled in a consumer report system (CRS) 

maintained by the state and distributed throughout the state’s One-Stop system. The 

establishment of ITAs is intended to empower customers, while promoting accountability 

among states, local areas, and service providers in meeting customers’ needs.

In the summer of 1999, DOL issued a Solicitation for Grant Applications (SGA) 

for the Individual Training Account/Eligible Training Provider (ITA/ETP) 

Demonstration. This announcement emphasized that DOL was interested in identifying 

“a national group of vanguard sites” who were committed to implementing ITAs and 

establishing an eligible training provider list that was consistent with WIA and “informed 

by best practice and insight from the field.” Chief goals of the demonstration include 

support for system-building at the state and local levels, rigorous testing of several key 

models or approaches to the establishment of an eligible training provider process and 

ITA payment system, identification of key components of effective ITA implementation, 

and the development of a learning network for information sharing, both across 

demonstration sites and to the larger employment and training system. Each grantee was 
ES-2

to receive an amount not in excess of $500,000, for a grant period that was to last 18 

months. 

In March of 2000, DOL announced that it had selected thirteen grantees to 

participate in the demonstration project. Six of these grantees are local workforce 

investment areas (LWIAs) that applied individually or on behalf of neighboring local 

areas. The other seven grantees are states. Of these seven states, four are collaborating 

with some subset of the state’s LWIAs, while the other three states are developing 

statewide systems and strategies.

The evaluation of the ITA/ETP Demonstration, being undertaken by Mathematica 

Policy Research (MPR) and Social Policy Research Associates (SPR), consists of a 

process study that entails two rounds of multi-day site visits to each of the thirteen 

grantees. Each site visit entails interviews at both the state and local levels, regardless of 

whether the grantee was itself a state or local area. The Interim Report for the evaluation, 

on which this summary is based, draws on the first round of site visits, which occurred in 

late summer and fall of 2000. Data collection will continue during the summer and fall 

of 2001, when each grantee will be visited a second time. At that time, we expect that 

service designs and ITA/ETP systems would have matured substantially. 

CONTEXT FOR THE DEMONSTRATION

Site visits to study the ITA/ETP demonstration grantees were conducted at a time 

when many of them were still developing key aspects of their systems. Moreover, for a 

variety of reasons—including fears of funding shortfalls, a strong economy that makes 

job placements relatively easy to obtain, One-Stop centers’ apprehension of authorizing 

training unless it was absolutely necessary, and the need to have customers go through 

core and intensive services before training could be offered—in some sites no more than 

a dozen customers had been issued an ITA, out of hundreds of WIA adult and dislocated 

worker enrollees. Clearly, the systems we saw were for the most part very much a work 

in progress. At the same time, all sites had made substantial progress, both in developing 

policies to serve customers with an ITA and in establishing an eligible provider list and 

consumer report system.

Their progress was facilitated because most were not starting their ITA system 

development from scratch when the ITA/ETP demonstration grants were awarded. In 

fact, almost all had moved sharply away from the exclusive use of contracted training in 

the waning years of JTPA and towards individual referral methods, and over one-half of 
ES-3

them claimed previous experience with using vouchers for training, either as a grantee 

under the former Career Management Account demonstration or as part of some other 

pilot program. One-Stop implementation grants that they had received from DOL during 

the mid- to late-1990s also helped them establish the infrastructure that they needed to 

serve adult and dislocated worker customers in a WIA framework. 

Building on this framework, the grantees were using their demonstration funding in 

very different ways, which reflected the nature and extent of their prior progress. Their 

grant objectives ranged from the very broad (e.g., develop ITA policies, build a consumer 

report system) to the quite specific (e.g., develop a code of ethics for vendors). In 

general, grantees that specified broader goals were not as far along in ITA/ETP system 

development at the time their grant proposals were prepared. By contrast, those that 

specified narrower goals had many elements of their systems already in place and were 

looking to enhance or refine them in some way.

Grant objectives can also be categorized with respect to their major area of focus. 

The most common cluster of objectives related to efforts to build electronic consumer 

report systems. Capacity building was another key objective, but the specifics varied. 

One grantee wanted to hire counseling experts to work with participants and coach case 

managers; another wanted to develop a curriculum for a peer-managed workshop; others 

wanted to develop and deliver training workshops for staff or develop computer modules 

that staff could access as a resource. The third largest category of grant objectives related 

to developing or testing ITA policies; for example, one grantee was trying to facilitate 

coordination and joint policy development with adjacent LWIAs. Finally, some grantees 

were using their grant funds to develop fiscal or tracking software or to automate the 

training provider application process.

CUSTOMERS’ USE OF ITAS

All of the grantees had embraced the ITA model for providing training services and 

generally seemed enthusiastic about its possibilities for empowering customers. In fact, 

nearly all of them were planning on using ITAs for training adults and dislocated workers 

almost exclusively; only two expected to make regular use of contracted training for 

meeting the needs of special populations. However, several expected a sharp drop-off in 

the number of persons they would fund for training each year, citing what they felt was 

WIA’s “work first” emphasis and funding limitations caused by their needing to expend 

resources on developing their core and intensive service strategies.
ES-4

Regardless of the customer volume that they anticipated, sites needed to develop 

policies to guide the way that customers move through core and intensive services, 

because only those who have received at least one service at each of these two service 

levels, without having their employment goals met, are eligible for training. The casestudy sites varied quite a bit with respect to the policies and procedures that they 

established for this purpose. Some noted that customers whom the case manager felt 

could obviously benefit from training were moved through core and intensive services 

quite quickly. Other sites had more stringent requirements before customers could move 

through to training—for example, by having case managers exhaust all reasonable 

possibilities that the customer might have transferable skills and/or requiring that 

customers spend at least several weeks in core and intensive services engaging in job 

search before training would be considered.

Another key difference across sites related to how intensive services were used as a 

prelude to training. Some sites felt that they could quickly (in core services) identify 

those who would need training services to meet their employment goals. Such 

individuals were placed in intensive services with the full expectation that they would 

shortly undertake training, so intensive services were focused on helping customers 

develop and refine their career and training plans. Other sites felt that intensive services 

represented another opportunity to identify transferable skills and improve job search 

strategies that might obviate the need for training altogether.

Despite these different general tendencies from one local area to the next, however, 

all the demonstration sites emphasized that guidelines were not meant to be followed 

rigidly and that they adopted a flexible approach to meeting customers’ needs. It seems, 

then, that a key tenet of WIA that services should be customer driven and based on the 

individual’s own needs appears to have been followed. 

The customer focus is evident as well in the process that sites use to help customers 

make training choices. We identified three models that sites use under various 

circumstances. These are informed choice, which occupies a broad middle ground, and, 

at either extreme, directed choice and free choice. According to the informed choice 

model, One-Stop centers ensure that those authorized for training receive ample 

information, guidance, and assistance, so that they can make prudent choices with respect 

to the occupation for which they want to be trained and the vendor who will provide it. 

This was by far the predominant mode in the sites we visited. Operationally, it meant 

that customers would be required to undertake a comprehensive assessment of their skills 
ES-5

and abilities, and engage in labor market and other research, before an ITA would be 

issued. Front-line staff play a key role in serving as “guides” or “facilitators,” striking 

what seemed to be an appropriate balance between lending the benefit of their expertise 

while not being overly directive. 

A key element that made the informed choice approach feasible was that 

assessment and research were required parts of the decision-making process. In addition 

to having participants undertake a comprehensive assessment and engage in labor market 

research, which were everywhere required, some sites required participants to conduct 

field research, such as by visiting several vendors and interviewing former trainees and 

employers who hire in the career area in which the participant wants to undertake 

training. Other sites required that customers attend workshops that are either given by 

case managers or are peer-managed. Sometimes also customers needed to submit a 

formal application, in which they identify the training field and vendor they have chosen 

and justify their decision on the basis of assessment results and the research they have 

conducted. As a consequence of following these steps to having their ITAs approved, 

customers would come to identify appropriate training choices on their own. 

By contrast, a “directed choice” approach was characterized by the case managers’ 

playing a much more directive role. Only one site used this model predominantly, 

although others would use it under special circumstances, as when customers seemed 

unable to make sense of their assessment results or were reluctant to make judgements 

based on the research they had conducted. In these instances, case managers could be 

quite emphatic in steering customers to the choices that the case manager thought best.

Finally, the third approach, a “free choice” model, was also used sparingly. 

According to this strategy, case managers would essentially give customers free reign to 

make training choices, so long as the training field was for an occupation in demand and 

the vendor appeared on the ETP list. No site used this approach predominantly. 

However, customers who knew exactly what training they wanted to undertake before 

entering the One-Stop center, and who could justify their choice, often had their request 

honored with little difficulty.

Given the predominance of the informed choice model, our interviews and 

observations lead us to the conclusion that customers are effectively the decision-makers 

almost always. However, their choice is subject to certain limitations established by state 

and local policy. For example, in keeping with the WIA legislation, training can only be 
ES-6

funded if it is for an occupation in demand. Some local areas met this requirement by 

drawing on lists developed by the state’s labor market information research unit. Other 

sites used locally-developed lists, and a few had no formal lists but instead relied on the 

judgement of the case managers. Typically, where there were such lists, exceptions could 

be made so long as a prospective trainee could present evidence that a job would be 

available once training was complete; however, a few local areas allowed no exceptions 

whatsoever.

Other restrictions related to dollar or time limits. Nearly all of the sites set a dollar 

cap on the amount of the ITA that would be funded, but these varied widely across sites, 

from a low of $1,700 to a high of $10,000. Tuition and fees, as well as books, uniform, 

and equipment would normally be funded by the ITA, and supportive services would be 

provided from a separate pot of money. In keeping with WIA, trainees were typically 

expected to apply for a Pell grant, and amounts they received from that source were often 

applied to the cost of the training, with the ITA paying any balance due. Nearly all sites 

also had time limits on the duration of training that they would support, which they 

usually set at two years. Overwhelmingly, both dollar and time limits were imposed by 

local areas; although they were allowed to impose limits of their own, states generally felt 

that these decisions should be left as a local prerogative.

Even with these limits, sites could be investing a substantial amount on each 

trainee. For that reason, and also because performance accountability is so central to 

WIA, sites had an interest in doing what they could to ensure that their ITA holders 

completed the training and obtained a well-paying job afterwards. Thus, all sites made 

provisions for keeping abreast of the trainee’s progress and attempted to address 

problems as they arose. Some sites were more proactive than others were, but virtually 

all maintained at least monthly contact with WIA participants in training. 

Given that their performance is publicly displayed as part of the consumer report 

system, vendors also have a clear stake in the trainee’s success, and thus they too played 

a part in monitoring the participant’s progress. Along these lines, proprietary schools—at 

least those that we visited as part of this study—seemed very attentive to students’ needs 

for extra assistance, and were aggressive in helping their students find jobs once the 

training was completed. By contrast, although community colleges offered counseling 

and placement services, they were typically less proactive in their approach. 
ES-7

DEVELOPING THE ETP LIST AND CONSUMER REPORT SYSTEM

A key element of the training system envisioned by WIA is for there to be clear 

accountability and strong information systems to support customer choice. The eligible 

training provider (ETP) list and consumer report system (CRS) constitute essential tools 

for these purposes. Developing the ETP list and consumer report system proved to be 

extraordinarily resource intensive. 

A key issue that states grappled with as they assembled the CRS was deciding 

whether only ITA-approved vendors should be included or whether it should include nonITA approved vendors as well. About half of the states adopted each approach. Those 

that were developing a restricted consumer report system emphasized the primary 

objective of supporting training customers in selecting a vendor; those that opted for the 

broader approach were giving emphasis to developing a resource for the universal 

customer in core services and making the broadest possible use of the resource they were 

developing. Using different logic, both also saw their approach as serving as an 

inducement for vendors to seek ITA eligibility. 

Regardless of the approach they took, sites were generally eager to widely 

publicize the ETP application process and have as many vendors apply for eligibility as 

possible. In some cases, states took the lead role, such as by sending an ETP application 

packet to all state-certified training vendors in the state. In other states, local areas took 

the lead role, such as by communicating with their former JTPA providers or holding 

informational sessions in the community. Most states attempted to automate the 

application process, both to make it easier for vendors to apply and also to expedite the 

state’s and local areas’ roles in processing applications and entering the data into an 

electronic ETP listing. Those states without an electronic application found the process 

substantially more burdensome.

Only two states set performance requirements for initial eligibility. The others 

dispensed with such requirements, because they felt ill equipped to make decisions 

regarding performance benchmarks at such an early stage. In general, vendors were not 

even required to submit performance data as part of their initial application. States felt 

that doing otherwise would impose a substantial burden on vendors that they were not yet 

prepared to meet.

In keeping with the legislation, the approval process for initial eligibility basically 

worked the same way in all the sites we visited—local areas would first review the 

applications, make a judgement of whether the application should be approved, and then 
ES-8

pass the application on to the state, along with the local area’s recommendation, for final 

disposition. The one difference was that some states had vendors submit their 

applications directly to the local areas, while other states had vendors submit their 

applications to a central state clearinghouse, which then forwarded the applications to the 

local areas for their review. The latter approach was viewed as easier for vendors, who 

would need to submit just one application for each of its programs rather than multiple 

applications to multiple local areas throughout the state; it also standardized the 

application process somewhat.

Regardless, a concern that local areas expressed was having a vendor’s application 

for eligibility denied by one local area but approved by an adjacent one. Given that ITA 

holders can hypothetically choose any vendor on the state list, presumably a trainee could 

thus select a vendor that the local area funding the ITA had disapproved. Several of the 

case-study sites were attempting to develop a regional approach to ETP review to 

eliminate this possibility. The case managers in another site admitted that they could not 

envision authorizing an ITA if the customer had selected a vendor that the local area had 

not approved, except under exceptional circumstances.

Another concern was that many states anticipated a sharp drop in the number of 

vendors who were approved once subsequent eligibility began. As mentioned, only two 

states imposed performance requirements for initial eligibility, deliberately with the 

thought that they wanted as many vendors to apply as possible. Similarly, few reporting 

requirements were imposed, beyond asking the vendors to provide basic information 

about each of their programs, such as the duration of training and its costs. But, for 

subsequent eligibility, vendors must be prepared to begin submitting performance 

information about their programs, relating to the completion rates and employment 

outcomes of trainees, including those that were WIA funded and others. Many vendors, 

especially community colleges, have balked at these requirements. They viewed the time 

and effort necessary to assemble the necessary information as not worth the trouble, 

given that they anticipate serving relatively few WIA-funded trainees. As openenrollment institutions serving diverse community needs, some community colleges also 

feel that their measured performance could misrepresent their actual success, given that 

some of their non-ITA enrollees might lack adequate preparation for training or others 

might not have employment objectives in mind.

Another reason why the ETP list under subsequent eligibility might be appreciably 

smaller than the initial list is that all states will presumably impose required performance 
ES-9

benchmarks for subsequent eligibility, while only two states did so for initial eligibility. 

Few states had made much progress in establishing guidelines for subsequent eligibility. 

All were grappling with where to strike the balance between setting the minimum 

requirements high enough to reflect their high expectations, while not setting them so 

high as to exclude so many vendors that participant choice is seriously compromised. 

Definitional issues were also presenting serious conceptual hurdles. For example, 

even at the point of initial eligibility states needed to make clear what would constitute a 

“program” for purposes of the ETP list. Thereafter, as they attempted to measure 

performance for subsequent eligibility, they needed to decide how key terms would be 

defined, such as who counts as enrolled and what constitutes a completion. Given the 

fact that many community college enrollees may take variable sequences of courses with 

different employment and other objectives in mind, states were generally allowing 

vendors to self-define programs and some were counting as enrollees only those who 

declared their intention to complete the entire sequence of courses that made up the 

program, with employment as the intended objective. 

Amassing the data to measure performance, however the measures were defined, 

also will prove challenging. In keeping with WIA requirements, states were planning on 

relying heavily on using Unemployment Insurance wage records for measuring outcomes 

that were employment related. Thus, vendors would forward the social security numbers 

of enrollees to the relevant state entity, who would then conduct the UI matching on the 

vendors’ behalf. This approach seemed to make the most sense from the standpoint of 

ensuring completeness, reliability, and comparability. However, the mechanics of this 

process were generally still being worked out.

In contrast to employment outcomes, where the states will bear most of the burden 

in data collection on the vendors’ behalf, most states are expecting vendors to supply data 

on their programs’ completion rates. One state, however, has agreed to compute even 

these rates for vendors, if the vendors will forward to the state the vendors’ enrollment 

database.

Because of the complications that needed to be resolved, at the time of our site 

visits only a few states’ systems had any information about vendors’ performance. 

Clearly, much work remains to be accomplished for the consumer report systems to fulfill 

their function of providing an important resource to guide customer choice. 
ES-10

VENDORS’ REACTION

In the local areas we studied nearly all training vendors certified as eligible for ETP 

purposes are either community colleges or proprietary schools. These two types of 

institutions have very different missions and define themselves very differently. The 

former have traditionally filled an important role in providing training under JTPA, 

because of the breadth of their offerings and generally low tuition, and it is expected that 

they will be similarly important under WIA. However, many are balking at the eligibility 

requirements that WIA imposes, especially the need to submit performance information 

about their programs. In their view, the low volume of ITA-funded trainees that they can 

anticipate does not warrant the time and expense that such a requirement would entail. 

They also fear that their performance would be inaccurately characterized, given the mix 

of customers that many of them serve.

By contrast, the proprietary schools whose representatives we met characterized 

themselves as being active in the marketplace and highly performance driven. For their 

own purposes, or to meet other state or federal certification requirements, these schools 

had been accustomed to collecting and reporting performance data and saw no difficulty 

with doing so for ETP purposes. They were also highly adaptable and flexible, 

modifying course content, starting times, and training durations to better appeal to 

potential trainees. 

Community-based institutions constitute a third group of potential vendors. While 

we did not visit with any community-based organizations that provide ITA training, 

Local Board and One-Stop staff noted that many of these organizations provided training 

to economically disadvantaged adults under JTPA, but are less likely to be successful 

under an ITA system because of their traditionally narrow customer base. Further, they 

are usually thinly capitalized and are likely to have difficulty coping with an irregular 

flow of ITA students. 

PRELIMINARY CONCLUSIONS

The full ITA and consumer report systems envisioned by WIA were still very much 

under development at the time our site visits occurred. Our upcoming second round of 

site visits, to be conducted in the summer and fall of 2001, will thus offer the important 

opportunity to view these systems as they have evolved. At this point, however, some 

preliminary conclusions can be drawn.

1. State and local-area flexibility seems to be embedded in the systems that are 

developing. Thus, although there are obvious broad similarities in the systems 
ES-11

that are developing, states and local areas are making unique decisions 

regarding key features of ITA policies.

2. That flexibility, although clearly embraced by states and local areas as a good 

thing, is causing some confusion and uncertainty at this early stage. Thus, 

some local areas are unsure exactly what their policies and systems should 

look like. In light of this uncertainty, more peer-to-peer exchanges would be 

highly valued, so that sites could share ideas and examples.

3. Overall, there is likely to be a substantial drop-off in the number of persons 

entering training, at least in WIA’s first full year of implementation. This 

drop-off will come about for a variety of reasons, including a strong economy 

that has made job opportunities plentiful, competing priorities for using scarce 

WIA funds, and case managers’ reluctance to authorize training unless it is 

absolutely necessary.

4. Sites are maintaining a strong customer focus in the way they approach WIA’s 

three service levels. Despite the reluctance in some cases to authorize training 

unless it is absolutely necessary, in general we observed that sites are highly 

flexible in their approach to customer services. Thus, although sites have 

guidelines for how customers should move through the service levels, it was 

apparent that those guidelines were not meant to be followed rigidly and that 

customers’ obvious needs were taking precedence.

5. Customer choice, informed by good information, is clearly apparent in the way 

that sites are working with customers to help them select training programs 

and vendors. At the same time, this choice is structured within a framework 

that requires that customers undertake a careful assessment of their skills and 

abilities and conduct extensive labor market and other research. To this 

degree, customers are making choices only after being exposed to a range of 

good information. 

6. Front-line staff are generally playing roles that support informed choice. In 

most local areas that we visited, case managers were playing the role of 

“facilitators,” and were lending the benefit of their expertise without being 

overly directive. To this degree, customer empowerment was being promoted. 

Given that many sites had moved away from contract training in JTPA’s 

waning years, and, in some cases, had previous experience with vouchers, case 

managers often felt that operating under an ITA system was not that much 

different from what they were accustomed to.

7. The underdeveloped state of most consumer report systems has meant that 

concrete and comparable information on vendor performance has not been one 

of the sources that most customers have been using in making their training 

decisions. Moreover, given the difficulties that lie ahead, with respect to data 

collection and data management, it will likely be some time before consumer 

report systems are reasonably populated with information about vendors’ 

performance. 
ES-12

8. Incentives for community colleges to participate in the ETP system need to be 

established. Proprietary schools as a whole have been very agreeable to the 

requirements that the eligibility process entails. Community colleges, by 

contrast, view these requirements as not worth the effort, given the few ITA 

customers that they anticipate serving, and their focus as educational 

institutions. Given the important role that these institutions play in giving ITA 

holders meaningful choice, sites need to develop strategies to keep community 

colleges as active players in the training marketplace.

9. The ITA/ETP process is presenting substantial challenges to training vendors 

that relied heavily on workforce development funding under JTPA. Reliant for 

so long on contract training for serving special populations, these 

organizations are finding that their customer flow has been gravely interrupted 

since the enactment of WIA. This challenge has fallen especially heavily on 

community-based organizations. Without an alternative customer base, many 

of these institutions are facing insolvency. Their absence will represent a 

substantial loss to their communities.

10. Processing vendors’ applications and developing the consumer report system 

are extraordinarily difficult and resource-intensive undertakings. In light of 

this, several grantees noted how fortunate they consider themselves to be in 

having been selected to participate in this demonstration, as it has provided 

them with access to special funds for system development that otherwise 

would have needed to come from their regular WIA formula allocation. This 

observation speaks to the difficulty that non-grantee states may be 

encountering with system development, and also for the need for states and 

local areas to develop systems that, once developed, can be sustained at 

minimal cost.
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I. INTRODUCTION

The Workforce Investment Act (WIA) of 1998 brought about substantial changes 

in services provided to persons seeking employment and training assistance. An 

important element of WIA is the requirement that training services be provided, with 

certain limited exceptions, through individual training accounts (ITAs), which provide 

vouchers or related funding vehicles customers can use to pay for training. The 

establishment of ITAs is intended to empower customers to make their own choices, 

while promoting accountability among states, local areas, and service providers in 

meeting customers’ needs.

To examine how ITAs are currently functioning and how they might be structured 

for maximum benefit, DOL has funded Mathematica Policy Research (MPR) and its 

subcontractor, Social Policy Research Associates (SPR), to conduct an evaluation. The 

evaluation consists of two distinct components. The first is a process study of thirteen 

federally-funded demonstration projects whose progress in establishing ITA and eligible 

training provider (ETP) systems and structures is being examined. The second 

component consists of an experimental evaluation of three distinct models of ITAs that 

vary in the amount of the voucher and the degree to which customer choice is guided by 

the case manager. This Interim Report describes our preliminary findings from the first 

of these two evaluation studies. 

The remainder of this chapter first describes the policy background related to ITAs 

and presents a conceptual framework for the evaluation. Then we summarize the process 

by which DOL selected the demonstration projects to be studied, and we briefly identify 

their salient commonalties and differences. The chapter concludes with a description of 

the research design and methods of data collection associated with our study.

INDIVIDUAL TRAINING ACCOUNTS IN THE CONTEXT OF WIA

The Workforce Investment Act substantially reshaped the nation’s employment and 

training system. One of the primary goals of the legislation is to empower customers to 

take control of their own career and training choices while providing them with the 

information and other supports that they need to choose wisely. One way that local job 

training agencies promote choice is by issuing individual training accounts to adults and 

dislocated workers who are undertaking training.
I-2

Services Available to Adults and Dislocated Workers

The WIA legislation requires the use of ITAs only for the adult and dislocated 

worker programs funded under Title I. As defined by WIA, Section 101, adults include 

all individuals who are 18 years of age or older. Dislocated workers are those who:

• Have been terminated or laid off (or received a notice of termination or 

layoff) from employment, are eligible for or have exhausted entitlement 

to unemployment compensation (or otherwise show attachment to the 

workforce), and are unlikely to return to their previous industry or 

occupation, or

• Have been terminated or laid off (or received a notice of termination or 

layoff) from employment as a result of any recent or impending 

permanent plant closure or substantial layoff, or

• Were self-employed but are now unemployed as a result of general 

economic conditions or because of a natural disaster, or

• Are displaced homemakers, defined to be those who have been providing 

unpaid services to family members in the home, have been dependent on 

the income of another family member but no longer are supported by that 

income, and are unemployed or underemployed and are experiencing 

difficulty in obtaining or upgrading employment.

The programs for adults and dislocated workers are separately funded, but both 

were authorized to increase the employment, retention, earnings, and occupational skills 

of participants and, as a result, “improve the quality of the workforce, reduce welfare 

dependency, and enhance the productivity and competitiveness of the nation” (WIA 

Section 106).1 To achieve these goals, adult and dislocated worker programs establish a 

hierarchy of three service levels that consists of core services, intensive services, and 

training services.

Core services consist of providing basic information primarily intended to assist 

individuals in conducting job search or accessing training or other services on their own. 

In keeping with this, activities authorized by the legislation (Section 134d) as core 

services include:

• Providing an orientation to services offered under WIA, 

 

1 Throughout this chapter, and elsewhere in the Report, we identify relevant sections of the WIA 

legislation or implementing regulations as found in the Code of Federal Regulations (CFR), as an aid to the 

reader.
I-3

• Providing an initial assessment of skill levels, aptitudes, abilities, and 

supportive services needs, 

• Providing job search and placement assistance, and, where appropriate, 

career counseling,

• Providing information on jobs in demand in the local economy and on 

eligible providers of training services,

• Describing procedures for how one can access unemployment 

compensation, and 

• Providing follow-up assistance to individuals who were served by the 

program and were placed in unsubsidized employment. 

All adults and dislocated workers are eligible to receive core services. Customers can 

access these services on their own (e.g., through electronic listings of information) or 

with minimal staff assistance.

Intensive services consist of activities involving somewhat greater staff 

involvement than is typical for core services, but the focus is still on providing 

participants with guidance or information that they need to make informed choices about 

their careers. For example, activities authorized as intensive services can include:

• Providing comprehensive and specialized assessments of participants’ 

skills or service needs, 

• Developing an individual employment plan for them,

• Providing group or individual counseling and (for participants undergoing 

training) case management,

• Delivering short-term prevocational services (e.g., assisting participants 

in developing interviewing skills, communication skills, personal 

maintenance skills, and the like). 

Only persons who have been unable to meet their employment objectives through core 

services will be eligible to participate in intensive services. Moreover, for participants 

served under the adult program, priority is given to public assistance recipients and other 

low-income individuals. 

Training services include skill-building activities that are designed to make 

participants more employable. Training activities that are explicitly authorized (WIA 

Section 134d) include:

• Occupational skills training,

• On-the-job training,
I-4

• Training programs operated by the private sector,

• Skill upgrading and retraining,

• Entrepreneurial training,

• Job readiness training, 

• Adult education and literacy activities (but only if provided in 

conjunction with another training service),

• Customized training for individuals to be hired by a specific employer.

Following a hierarchy of service levels, training services are available only to those who 

have undertaken at least one intensive service without it meeting their employment goals. 

Additionally, persons are funded for training only if they are deemed to have the skills 

necessary to succeed in training, select a program of training for jobs that are available, 

and require assistance beyond what is available from other sources (e.g., Pell grants). As 

with intensive services, those funded through the adult program receive priority for 

training if they are public assistance recipients or other low-income individuals.

With respect to service delivery, core services are to be provided through a OneStop delivery system, which includes at least one comprehensive One-Stop Center in 

each local workforce investment area and potentially a network of affiliated sites. 

Intensive services are also to be made available through the One-Stop delivery system, 

either directly or through contracts with service providers. In contrast, training services 

will generally be delivered by establishing an individual training account that the 

customer can use to procure training services from eligible training providers. Local 

workforce investment areas are required to use ITAs to provide training, except in some 

specified circumstances. As specified by WIA (Section 134d4G), these exceptions 

include contracts that the local area can write to fund:

• On-the-job training or customized training provided by an employer,

• Training programs by community-based organizations or other private 

organizations that are of demonstrated effectiveness in serving “special 

participant populations that face multiple barriers to employment,” or

• Other providers, if it is deemed that there are too few providers in the area 

to fulfill the intent of ITAs. 

Role of Individual Training Accounts and Training Providers

ITAs are intended to transform the delivery of training services to adults and 

dislocated workers by ensuring customer choice. In this regard, once issued an ITA a 

customer will generally be free to use it to procure the training services of his or her 
I-5

choice, subject to some restrictions. First, as noted above, training must be directly 

linked to employment opportunities in the local area (or in another area in which the 

participant is willing to reside). Second, states and local areas may place restrictions on 

the duration of training that can be undertaken and on its costs (20 CFR 663.420). Third, 

customers may use their ITA only for approved training programs. To attain this 

classification for one or more of its training programs, the training provider must have: 1) 

submitted an application for the program to appear on the eligible training provider list, 

2) agreed to provide information on program costs and on the performance of recent 

trainees for each training program in which the provider wishes to be certified as eligible, 

and 3) meet certain performance benchmarks established by the state and local area. 

With respect to provider eligibility, the state is responsible for developing the 

overall procedures. As outlined in the Act (Section 122), these responsibilities inc lude 

establishing procedures for initial and subsequent eligibility. The procedure for initial 

eligibility is different for postsecondary educational institutions than for other providers. 

Postsecondary educational institutions that award a degree or certificate and are eligible 

to receive funds under the Higher Education Act are to be considered initially eligible, as 

long as they submit an application to the local area containing the information required 

by that area. However, other providers, in their application for initial eligibility, may be 

asked to submit program-specific information about the costs of their training services 

and the outcomes achieved by former trainees, and have met performance levels if 

required to do so by the state.2 The state is to establish these requirements after a 

consultation process involving Local Boards, business, and labor.

Initial eligibility can last from 12 to 18 months. Thereafter, all providers who seek 

certification, including postsecondary degree-granting institutions, must submit 

performance and cost information and meet performance criteria annually, in order to 

maintain subsequent eligibility (WIA Section 122c and d). This performance information 

should cover:

• Outcomes achieved by all individuals who participated in the programs 

for which the provider is seeking certification, including:

− The percentage of those participating who completed the training.

− The percentage of those participating who obtained unsubsidized 

employment.

 

2 New training programs are, however, exempted from meeting the performance criteria.
I-6

− The wages at placement of all individuals who participated.

• Outcomes achieved by individuals funded by WIA who participated in the 

programs for which the provider is seeking certification, including:

− The percentage of those participating who completed the training 

and obtained unsubsidized employment.

− The percentage of those who completed the training who were 

found to be in unsubsidized employment six months after being 

placed in employment.

− Wages received by those who completed the training, measured 

six months after the first day of the employment involved.

− If applicable, the percentage of graduates who obtained a license 

or certificate, an academic degree or equivalent, or other measures 

of skills.

The required performance levels on these measures are established by the states, although 

local areas can establish higher levels. In any case, the levels established for a provider 

should take into account characteristics of the local economy and of the persons it serves. 

Performance information on the employment measures must be compiled using data from 

the Unemployment Insurance (UI) system. 

According to WIA, the local boards should review all applications, whether for 

initial or subsequent eligibility, and then forward the list of providers they have approved 

to the state. The state, in turn, is to check the performance data for accuracy and compile 

a master state eligible training provider list, which is disseminated to all local areas along 

with the cost and performance data. This complete information packet is referred to as 

the “consumer report system,” and should include any additional information “necessary 

for an adult or dislocated worker customer to fully understand the options available to 

him or her in choosing a program of training services” (20 CFR 633.570). 

CONCEPTUAL MODEL FOR THE EVALUATION

The use of ITAs represents a dramatic shift in the way in which training services 

are delivered, with potentially important implications for the ways in which One-Stop 

Centers, vendors, and customers relate to each other. However, although the broad 

guidelines described above are prescribed by the WIA legislation and implementing 

regulations, states and local workforce investment boards have substantial discretion in 

how ITAs are developed and used in practice, for example with regard to the 

performance levels required of eligible providers, the information included in consumer 

report systems, the types of customers for whom training services are deemed 
I-7

appropriate, the guidance customers are given to assist them in making training choices, 

the ways in which vendors are monitored, and the types and duration of training that is 

considered “fundable.” To help us understand this variability, and how it impacts the 

delivery of training services, we have developed two heuristic models. The first is a 

system-level model of ITA implementation, depicting how the system of training services 

might be expected to develop. The second model depicts a customer-level view of how 

clients might flow through the system, and it identifies quality indicators for the various 

steps of the process.

System-Level Model of ITA Implementation

ITA implementation represents a wholesale transformation of how the various 

actors in the training system—including the federal and state governments, local 

workforce boards, and vendors—relate to one another. An important objective of this 

evaluation is to describe these changes. To clarify these interrelationships, we outline 

below the roles the various actors are expected to play.

The Federal Role. The WIA legislation itself and the implementing regulations 

developed by DOL constitute the broad guidelines within which the ITA system will 

develop. Because the legislation and regulations will not vary, at least over the shortterm, they constitute a context for the development of the ITA system rather than an 

important source of site-to-site variation. Nonetheless, the guidance that DOL issues and 

the training and technical assistance it provides can be expected to evolve over time, 

partly in response to input from states and local areas as they grapple with the 

practicalities of implementation. 

State Decisions and Influences. Under the WIA legislation, Governors play an 

important role in setting guidelines for their local workforce investment areas’ use of 

ITAs. Their responsibilities include establishing criteria for determining the eligibility of 

training providers, both initially and subsequently. As part of the certification process, 

states also develop monitoring and enforcement procedures to ensure that providers 

report information accurately and comparably. Similarly, procedures for sanctioning 

providers who report inaccurately or whose performance slips below specified thresholds 

must also be developed. Finally, with respect to certification, the state designation board 

maintains and updates the state-approved list of eligible training providers and 

disseminates the list along with each provider’s performance and cost information. States 

may vary in the procedures they establish for these purposes, including how local boards 

(and potential trainees) access the list, how the list is updated, and the ways in which 
I-8

performance and cost information are conveyed to allow meaningful comparisons across 

programs of different types. Some states might also include on a master list providers 

who are not deemed eligible under WIA Title I; the advantages of doing so would be to 

make available a comprehensive information tool to be used by customers in core 

services or by partner programs.

States can also set limits on the types or duration of training that will be funded (20 

CFR 633.420). States may establish these restrictions as upper limits on either the length 

of training that will be supported, the costs incurred, or both. Or they may establish 

limits for individual customers based on their training needs (e.g., depending on which 

field of study they are undertaking). Similarly, they can restrict the period of time over 

which trainees can access funds in their training accounts. An important objective of the 

evaluation is to understand how and why these decisions were made and to track their 

implications for the design and delivery of training services at the local level and from 

the standpoint of ensuring customer choice.

An additional state role lies in training and capacity building. The WIA legislation 

(Section 134a) gives states discretion to use their WIA funds for these purposes, 

including providing assistance and training to One-Stop operators, One-Stop partners, 

and eligible providers. The type of assistance that is provided can clearly be expected to 

influence the service delivery process.

By way of establishing a context, it is also important to note the prior progress that 

states have made in implementing many of the tenets of WIA. Although ITAs represent a 

relatively new development in the delivery of workforce training, many states had 

already made substantial progress towards implementing a One-Stop service delivery 

system during the last few years of the Job Training Partnership Act (JTPA), which WIA 

replaces. As part of this process, many developed highly detailed data banks with 

sophisticated user interfaces to help customers make career choices and access 

information about training providers.3 Thus, as the demonstration begins, states find 

themselves at uneven stages in the development of the infrastructure that WIA mandates. 

Their recent experience with One-Stop implementation, which was in progress at the time 

 

3 DOL awarded One-Stop implementation grants to states and local areas in the several years before 

WIA was enacted. The first round of implementation grants to nine states was awarded by PY 95. 

Additional states received grants in waves from subsequent rounds of funding through PY 98. 
I-9

DOL awarded the demonstration grants, and the data systems that had already been 

constructed are important for understanding subsequent developments.

Influences and Responses of the Local Areas. Local boards are responsible for 

implementing an ITA/ETP system that meets state and federal guidelines, while being 

responsive to the needs of their customers. As part of their responsibilities, these boards 

must identify providers who are designated as eligible vendors according to the criteria 

established by the Governor, and they can impose additional performance criteria. In 

addition, they may impose limits on the types of training that will be funded (e.g., to 

ensure that the proposed training is directly linked to employment opportunities in the 

area) and the dollar amount of training that will be funded for different types of 

customers. 

Payment mechanisms that local areas establish might also vary, including how and 

when payments are made to providers. Evidence from the Career Management Account 

(CMA) Demonstration, which tested ITA-like procedures, suggests that different funding 

mechanisms can be used, including credit card-like transactions, a checkbook or 

payment-coupon system, and trainee identification cards to establish eligibility.4 

Similarly, payments can be tied to benchmarks relating to the trainees’ performance (e.g., 

satisfactory attendance or progress must be maintained).

Local Boards also have discretion in determining whether and under what 

circumstances exceptions to the use of ITAs will be considered. Such instances might 

include when there are an insufficient number of eligible providers in the area or a CBO 

of demonstrated effectiveness in serving special populations is identified. Conversely, a 

Local Board may decide to extend the use of ITAs to customers beyond those served with 

WIA Title I funds, such as for persons undergoing training funded by a partner program.

Staff members of One-Stop Centers also have substantial discretion in determining 

who is eligible for training services. Given stipulations in the legislation, decisions must 

be made regarding who is in need of and able to successfully complete training, and in 

what manner priority for public assistance and other low-income individuals will be 

established from among those served in the adult program. Similarly, because only those 

who have received core and intensive services without having their needs met are eligible 

 

4 The CMA Demonstration was launched in the summer of 1995 when DOL awarded grants to 13 

local areas.
I-10

for training services, we need to understand how services are tiered within the One-Stop 

Center and how customers move through the various service levels. Finally, within the 

framework of providing customers with the information they need to make informed 

decisions, counselors perform the important role of helping customers interpret 

assessment results, assisting them in developing an individual employment plan, and 

weighing the advantages of choosing from among alternative providers. Results from the 

CMA Demonstration suggest that some case managers have difficulty providing helpful 

guidance along these lines while relinquishing control over the ultimate decision-making.

Local areas’ prior experience with voucher-like systems is also important to this 

evaluation. For example, some sites selected for the evaluation have participated in the 

CMA Demonstration. Following many of the principles of ITAs, this demonstration was 

similarly designed to increase customer choice while allowing individuals to control their 

career and training plan. Obviously, lessons local areas have learned from this prior 

experience will influence developments under the current demonstration. More broadly, 

many local areas had already moved away from class-size training and towards individual 

referrals in the last several years of JTPA.

Finally, as part of the efforts that they have already undertaken to promote selfservices within a One-Stop context, some local workforce investment areas have begun 

assembling information about training providers, including data concerning provider 

performance. Other local areas, by contrast, are just beginning the process.

Vendors’ Influences and Responses. Under the ITA system, vendors’ roles and 

relationships to other actors have changed dramatically in comparison to the situation that 

was typical under JTPA. Under WIA, vendors who are interested in being certified as 

eligible have a primary obligation to demonstrate their effectiveness to the state and local 

boards, as evidenced by their program completion rates, employment rates, wages at 

placement, or other information required by the eligible provider system. Accordingly, if 

they have not already done so, vendors must develop and maintain the data systems 

necessary to track their performance. 

Vendors may also have an interest in marketing their services directly to 

prospective trainees, who now have much more discretion than previously in choosing 

the training venue that they feel is most appropriate. Vendors may also respond by 

modifying course offerings, training duration, and fee structures to make their offerings 

more appealing to consumers. 
I-11

Customer-Level Model of Training

In addition to understanding the policies and procedures that states and local areas 

develop, an objective of this evaluation is to examine how customers access training and 

the types of choices they make. To provide a framework for evaluating this process, we 

draw on indicators of high-quality service planning that we have developed and applied 

in many of our previous evaluations for DOL. 5

Levels of Service. To understand fully the assistance that trainees receive, we need 

to examine what core and intensive services have been provided before the customer 

accessed training services. According to WIA, only those who have been provided at 

least one core service and one intensive service are eligible to receive training services. 

Local areas might have very different policies regarding what core and intensive services 

are provided and for what duration, before access to training services is permitted. For 

example, in some cases, one core and one intensive service might be provided quickly—

even in a single visit to the One-Stop Center, when it is clear that a customer will need 

training services to be successful in the labor market. In other local areas, a more 

protracted service sequence may be required. Thus, customers may have had very 

different service histories before an ITA is issued.

Assessment and Service Planning. Customers undertaking training will normally 

have an individual employment plan (IEP). As defined by the WIA regulations, the IEP 

should be jointly developed by the participant and the case manager and identify “the 

participant’s employment goals, the appropriate achievement objectives, and the 

appropriate combination of services for the participant to achieve the employment goals” 

(WIA Section 134d3C).

Under WIA, customers have a substantial new responsibility in developing the IEP

and carrying it out. Case managers, in turn, have an obligation to provide potential 

trainees with the guidance and information to enable them to make informed choices. As 

part of a high-quality service-planning process, customers should be provided with a 

comprehensive assessment of their basic and occupational skills, interests, and aptitudes, 

leading to a determination of what skills the customer already possesses and which 

additional ones are needed to ensure competitive performance in the labor market. The 

assessment should lead to a determination about whether or not additional training is 

 

5 See, for example, A Guide to Well-Developed Services for Dislocated Workers, ETA Research and 

Evaluation Report Series, 1994.
I-12

desirable and, if so, for what type of training the customer is best suited. At the same 

time, supportive service needs should be evaluated, so that potential barriers to a 

customer’s successful completion of training can be redressed.

Customers consult with their case managers using the assessment results as a tool 

in developing the IEP. As a first step, case managers can provide career counseling and 

assist the customer in career exploration. A high-quality IEP should then clearly identify 

the customer’s short- and longer-term employment goals and the training objectives for 

achieving those goals, including interim benchmarks. The plan should be tailored to the 

skills, interests, and background of each participant, and should involve the customer in 

the service planning process. Finally, the IEP should establish high yet realistic 

expectations for learning and employment success, and should establish clear and 

appropriate goals that the participant is committed to achieving. With respect to training, 

case managers must balance the need to guide the participant in his or her decisionmaking while allowing for maximum customer choice; how this balance is struck may 

vary across local areas, and, within each area, from case manager to case manager.

Linking with Other Funding Sources. According to the WIA legislation (Section 

134d4B), program operators are expected to coordinate training funds that might be 

available from other sources, including Pell grants. To ensure that WIA funds are used 

most effectively, case managers should therefore explore these alternative funding 

sources with participants and assist them in accessing these sources whenever feasible. 

Similarly, WIA funds are to be used for meeting supportive service needs only when 

participants are unable to have their needs met through other sources. These strictures 

thus impose the responsibility on program operators to work collaboratively with other 

funding agencies and to leverage other resources when feasible. Thus, it is important to 

document what non-ITA resources customers have access to and from what sources they 

derive.

Training Content, Duration, and Quality. As part of the evaluation, we also 

need to understand what types of training customers actually undertake. One reason that 

training choices will vary across sites is because the extent of empowerment engendered 

by ITAs will also vary. For example, in some local areas ITAs may present customers 

with a bewildering array of choices, while in places with few vendors customer choice 

will be quite limited. Even in areas with extensive choice, customers must negotiate with 

their counselors to complete a training plan that adheres to state and local policy 
I-13

guidelines (e.g., based on what occupations are determined to be in demand, with respect 

to limits on costs or duration of training, etc.). 

We also need to document how customers make choices, based on what 

information is provided to them. This information can include assessment results, 

discussed above, but also the consumer report system, which is designed to provide 

customers with rich information about vendor performance and costs, along with 

additional data that may help them make a training choice. Customers may also respond 

to marketing appeals made by vendors, or have strong prior preferences about what 

training they want to undertake. Accordingly, some individuals may be little influenced 

by either vendor performance, assessment results, or the advice and guidance provided by 

a counselor, and instead rely on more “subjective factors” in making their decisions. 

How these diverse factors interplay in leading to training choices and how they vary 

across local areas are key areas of inquiry for this evaluation. 

GRANTEES SELECTED FOR THE DEMONSTRATION

In the summer of 1999, DOL issued a Solicitation for Grant Applications (SGA) 

for the Individual Training Account/Eligible Training Provider (ITA/ETP) Demonstration 

(SGA/DFA 99-017). This announcement emphasized that DOL was interested in 

identifying “a national group of vanguard sites” who were committed to implementing 

ITAs and establishing an eligible provider list that was consistent with WIA and 

“informed by best practice and insight from the field.” Chief goals of the demonstration 

include:

• Support for system-building at the state and local levels.

• Rigorous testing of several key models or approaches to the establishment 

of an eligible training provider process and ITA payment system.

• Identification of key components of effective ITA implementation.

• Support for demonstration “learning laboratory” sites in designing and 

implementing innovative processes and systems.

• Development of a learning network for information sharing, both across 

demonstration sites and to the larger employment and training system.

Each grantee was to receive an amount not in excess of $500,000, for a grant period 

that was to last 18 months. In support of the demonstration’s goals, the SGA stipulated 

that funds could be used for a variety of activities, including:
I-14

• Designing and delivering in-service training courses that would help case 

managers understand their new role in supporting customer decisionmaking.

• Developing orientation sessions to help customers understand their 

opportunities and responsibilities.

• Developing orientation sessions on ITAs and the eligible provider process 

for vendors.

• Developing a system to track training provider performance.

• Developing an ITA expenditure reporting system to provide individuals 

with information on the status of their account balances.

• Supporting related efforts associated with implementing ITAs and the 

eligible training provider system, including travel for staff.

The SGA emphasized that funds were not intended to be used for direct training 

expenditures of customers, but rather for “building the ITA/Eligible Provider system.” 

However, grantees were allowed to use up to 20% of their grant award to fund such 

training, to supplement other funds that would also be used for this purpose.

To be consistent with the intent of the WIA legislation, DOL noted that plans for 

ITA systems being proposed by bidders would need to adhere to a number of guidelines 

on which substantive variability could not be allowed. Thus, all grantees would be 

required to include all adult ITA participants in the demonstration, inform participants of 

the dollar amount available in their ITA accounts, make available the performance and 

cost information on vendors that WIA requires, pay vendors on a timely basis, develop an 

IEP for each individual undertaking training, and inform staff of the role they are 

expected to play in the ITA process. Additionally, bidders were informed that they 

would be expected to administer a common customer satisfaction survey to both all 

participants and all staff.

There was nonetheless quite a lot of room for variability in the systems that 

grantees could establish, including with respect to these key features:

• How the dollar amount of the ITA is determined (e.g., fixed for all 

participants or varying by assessment results).

• Who approves the ITA (e.g., a counselor, a committee, etc.).

• What career direction is allowed and how informed choice is provided 

(e.g., how much leeway are customers given in choosing a career 

direction, how are demand occupations identified, what is the role of the 

case manager).
I-15

• Who has final authority on selection of the training provider.

• What the ITA can pay for.

Applicants responded to these guidelines and, on March 27, 2000, DOL announced 

that it had selected thirteen grantees to participate in the demonstration project. These are 

identified in Exhibit I-1. As the exhibit shows, the grantees differ with respect to the 

nature of the partnership that applied for the grant. Thus, six grantees are local workforce 

investment areas (LWIAs) that applied individually or on behalf of neighboring local 

areas. The other seven grantees are states. Of these seven, four are collaborating with 

some subset of the state’s LWIAs, while the other three states are developing statewide 

systems and strategies. 

RESEARCH DESIGN AND DATA COLLECTION

To investigate the issues described earlier in this chapter, the evaluation of the 

ITA/ETP Demonstration consists of a process study that entails two rounds of multi-day 

site visits to each of the thirteen grantees. In general, each site visit will entail interviews 

at both the state and local levels, regardless of whether the grantee was itself a state or 

local area. We believe that this approach is sensible given the inevitable interplay 

between state and local decisions, in keeping with legislative requirements. Nonetheless, 

because the grantees are so different with respect to whether the primary activity 

associated with the grant is at the state or local level, we will “customize” the site visit 

agenda to spend more of the time on site at the grantee’s own level (i.e., by spending more 

time at the state level and less time at the local level for state grantees, and vice versa for 

grantees that are local areas).

The first round of site visits, which occurred in late summer and fall of 2000, forms 

the cornerstone for this report. Overall, the objectives of these visits were to understand 

states’ and local areas' efforts at implementing the ITA and ETP systems, impediments to 

implementation that were encountered, and variations in key elements of the emerging 

systems. In investigating these issues, we engaged in approximately three days of data 

collection associated with each grantee that entailed:

• A review of written guidelines and plans regarding the use of ITAs.

• Discussions with the demonstration grant administrator.

• Discussions at the state level with administrators responsible for the 

ITA/ETP system, to learn about the process and procedures that states 

have established.
Exhibit I-1

ITA/ETP Grantees and Local Areas Selected for the First Round of Data Collection

Grantee Area Partners Local Areas Visited for First-Round Site Visit

Grantees that are Local Areas 

Baltimore Office of Employment 

Development

A single LWIA acting alone • Baltimore

Indianapolis PIC Collaborating with the state and 3 other 

LWIAs..

• Indianapolis (IPIC)

• Tecumseh Area Partnership (TAP)

Macomb/St. Clair Workforce 

Development Board

A single LWIA acting with input from 

nearby LWIAs

• Macomb/St. Clair

• Washtenow

Metro Portland (worksystems) A single LWIA acting alone • Metro Portland

Southeast Los Angeles County 

(SELACO)

A single LWIA acting alone • SELACO

Southwest Connecticut (The 

Workplace)

A single LWIA acting alone • Southwest Connecticut

Grantees that are States

Georgia Department of Labor State will collaborate with two local 

areas

• Several LWIAs in Metro Atlanta (Atlanta 

Regional Commission)

Missouri Division of Workforce 

Development

All 15 LWIAs in state will provide input • West Central (Sedalia)

Nebraska Department of Labor All 3 LWIAs in state will provide input • Greater Lincoln

• Greater Omaha

North Carolina Department of 

Commerce 

State will collaborate with all LWIAs; a 

few will serve as test sites

• Capital Area (Raleigh)

Ohio Bureau of Employment 

Services

State will collaborate with two local 

areas 

• Cincinnati (part of Workforce 

Investment Area 7)

Pennsylvania Department of 

Labor and Industry

State will collaborate with 5 LWIAs. • Three Rivers Workforce Board (two 

LWIAs, Pittsburgh and Allegheny County)

Texas Workforce Commission State will collaborate with 7 LWIAs. • Heart of Texas

• Golden Crescent
I-17

• Discussions with state and local MIS staff, to learn about the computer 

interface for the consumer report system, tracking, and the like. 

• Discussions with local WIB staff and administrators of the One-Stop 

Center, to learn how the local area has provided input into the state 

guidelines regarding ITAs and what additional guidelines the area has 

established on its own, and how these guidelines have been implemented.

• Discussions with case managers and counselors, to understand the client 

flow-through process, including what types of assistance clients are given 

in making their training choices.

• Meetings with approximately two vendors, to discuss the ways in which 

they have responded to the WIA requirements.

Because all first-round site visits entailed data collection at both the state and local 

levels, a key decision involved deciding which local area or areas should be visited in 

conjunction with the study of state grantees. These areas were selected in consultation 

with the state ITA/ETP grant administrator and generally consisted of local areas that had 

some responsibility for carrying out the state’s grant activities. Exhibit I-1, which was 

previously referred to, identifies these choices.

Although this Report is based on the first round of site visits, data collection will 

continue during the summer and fall of 2001, when each grantee will be visited a second 

time. Because the first round of site visits will have established the context in which 

grantees are operating, the second round of site visits will focus on the evolution of the 

ITA and ETP systems and on the actual process of service delivery at the local level. 

Thus, during the return visits more attention will be focused on the local level, even for 

grantees that are states, so that we can better understand the process by which clients flow 

through the system, their reaction to the ITA system, and the characteristics and quality 

of the services that result. In general, for state-level grantees we will visit local areas 

during the second round of data collection that are different from those we visited during 

the first round.

This Interim Report was prepared for DOL and is intended as a comprehensive 

account of the first round of data collection. It includes, in Chapter II, a discussion of the 

context for implementation, by reviewing the grantees’ grant plans and their prior 

experience with vouchers and progress towards WIA implementation. Chapter III 

provides a discussion of ITA policies and procedures, including the priority given to 

training services, limits on the use of ITAs, and the client flow-through process with a 

focus on how customers become eligible to access an ITA and how they make their 

training choices. Chapter IV discusses the infrastructure supporting the ITA system, 
I-18

including how vendors became eligible to provide training services and how vendor 

performance data are being collected and displayed to customers. The vendors’ response 

to the ITA/ETP system then becomes the focus for Chapter V. Finally, Chapter VI 

concludes the Report with some summary observations. The Final Report, to be 

completed early in the year 2002, will provide a detailed accounting of the study’s 

findings, using information gathered from both rounds of data collection. 
II-1

II. GRANT PLANS AND IMPLEMENTATION PROGRESS

As discussed in the previous chapter, our evaluation focuses on the thirteen 

grantees selected to participate in the ITA/ETP demonstration. At the time these grants 

were awarded, the grantees differed with respect to their prior experience in using 

vouchers and, in general, with their readiness to operate under WIA guidelines. Partly 

for this reason, they articulated different objectives as part of their grant plans and 

experienced varied success in carrying out the ir grant objectives. To set the stage for the 

report’s subsequent chapters, we now describe these differences.

THE GRANTEES’ PRIOR EXPERIENCE AND READINESS

At least in principle, the use of ITAs, along with the concomitant obligation for 

states to identify eligible providers and develop a consumer report system, could 

represent a substantial transformation in the way training services are delivered. Along 

these lines, and in keeping with the principles of WIA, customers can become 

empowered to take control of their own training choices. Conversely, case managers 

need to adopt a coaching approach in working with their customers, rather than making 

decisions for them. The use of ITAs consistent with WIA also necessitates substantial 

effort towards building and managing information systems, such as in processing 

vendors’ applications for eligibility, amassing information required for the consumer 

report system, developing searchable databases for customers to use in identifying and 

comparing eligible training providers, and building systems to track the commitment and 

expenditures of vouchers. These tasks are all potentially enormously challenging.

The extent to which they were so in fact, however, was contingent on both the 

grantees’ prior experience with using voucher-like systems for training and their prior 

state of WIA readiness.

Prior Experience with Using Vouchers

A key provision of the system of training for adults and dislocated workers 

mandated by WIA enables prospective trainees to select a program of study and a training 

vendor that best meet their individual needs. This method for delivering training services 

stands in contrast to arrangements common under JTPA, whereby job training agencies 

contracted with training providers to deliver class-size training customized to a cohort of 

JTPA trainees. Although contracted training is still allowable under WIA, this legislation 
II-2

makes clear that such arrangements should be developed only under certain limited 

circumstances.

However, in actuality most of the ITA/ETP grantees had gradually moved away 

from the widespread use of contracted class-size training during JTPA’s waning years. In 

its place, customers were typically enrolled in occupational skills classroom training on 

an individual-referral basis. Indeed, one site claimed to have predominantly used 

individual referrals for training for decades and that over 95% of its JTPA training was 

conducted this way.

Even more importantly, prior to the onset of the ITA/ETP Demonstration at least 

eight sites had explicitly used vouchers for arranging at least some training. The most 

common vehicle for doing so was as part of the Career Management Account (CMA) 

Demonstration, described in the previous chapter. This demonstration project was 

designed to test the feasibility of providing training for dislocated workers through 

vouchers, so that customers would have maximum flexibility in selecting programs of 

study and training sources. A half-dozen ITA/ETP grantees (or their local-area partner) 

participated in CMA, either as a direct grantee or as a member of a consortium; these 

include Metro Portland, Baltimore, the Atlanta Regional Commission, Missouri (SDA II), 

Texas (East Texas), and Ohio (Cincinnati). 

Some ITA/ETP grantees also noted that they had even earlier experience with using 

vouchers. In some cases, this experience is long-standing and far-reaching. For example, 

the Atlanta Regional Commission first began using vouchers as a way of providing 

training services to the approximately 13,000 workers who were dislocated in 1991 when 

Eastern Airlines went bankrupt. Given its existing infrastructure and the size of the 

dislocation, this local area was facing many more prospective trainees than it could 

readily serve with class-size training. As a result, it used a voucher system and largely let 

dislocated workers choose whatever training they wanted. Similarly, Metro Portland has 

a strong history of using vouchers. In addition to its participation in the CMA 

demonstration (as part of a consortium), this local area has embraced what it calls 

Individual Learning Accounts in a major way over the last several years. Like ITAs, 

Learning Accounts represent efforts to put money in the hands of social service 
II-3

customers, who can then use these funds to advance their careers through continuing 

training and education. 1 

The prior experience that many of the grantees have had with voucher systems and 

individual referrals for training left them much better prepared for adopting ITAs as the 

mechanism for providing training under WIA than would otherwise have been the case. 

For example, respondents at several of our case-study sites remarked that case managers 

had moved years ago to adopt a coaching approach to helping customers make training 

choices. As a result, they felt that, although the transition was difficult at the time, ITAs 

meant little change to the way they have been doing business over the previous several 

years. For example, Baltimore moved to implement a voucher system when it became a 

CMA demonstration grantee in 1995 and has stuck with this approach ever since. As part 

of the CMA experience, the workforce area facilitated a change in the way case managers 

performed their job, from being “paper-pushers” under JTPA, to becoming empowered to 

make decisions regarding how to serve clients as individuals with unique needs. Some 

case managers found this transition difficult, and some are still adapting to their new role, 

but the bulk of the turmoil associated with the readjustment occurred before WIA 

implementation.

Additionally, information systems of the kind envisioned by WIA’s call for a 

consumer report system were already under development in some cases. For example, 

the Atlanta Regional Commission found that many of the dislocated workers whom it 

served through vouchers as part of the Eastern Airlines bankruptcy had made poor 

training choices (e.g., cosmetology, bartending, and other jobs with poor career 

prospects). Consequently, it began to systematically build a vendor list and carefully 

monitor vendor performance, so that it could provide vendors’ performance information 

directly to participants. Subsequently, by participating in the CMA demonstration it was 

able to further develop and systemize its procedures. Similarly, Pittsburgh shifted from 

class-size training to what the city’s WIA manager termed a voucher system in 1996. As 

part of this process, the local Private Industry Council developed a performance review 

system for training vendors, known as the Singh report. The report was widely accepted 

 

1 Typically, Learning Account customers make regular contributions to their account, and these are 

matched by contributions made by employers and social service agencies. Funds can then be used to pay 

for education and training expenses.
II-4

by program administrators as a powerful tool to aid customers in identifying effective and 

ineffective programs.

Although grantees that had prior experience with vouchers had a head start towards 

ITA implementation, the transition has not been entirely trouble-free. One grantee, for 

example, noted that serving exclusively dislocated workers with vouchers, as it did under 

CMA, turns out to be a very different experience than serving low-income or welfare 

adults with ITAs, as it is doing under WIA. Customers in the former group, this grantee 

feels, are much more self-sufficient and need much less assistance and support than those 

in the latter group. Accordingly, the “light-touch” services that it had in place to move 

dislocated workers through the service levels, from self-directed job search to assessment 

and then referral for training, needed to be substantially intensified to meet the needs of 

low-income adults. Other grantees noted that, although case managers may had already 

come to adopt a coaching role to helping customers make training choices, WIA 

represented a new environment in which to do so. Under JTPA, for example, customers 

and case managers shared the presumption that all customers who came in for services 

would undergo training. By contrast, WIA, with its stipulations that training should be 

considered only when core and intensive services were unable to yield satisfactory 

results, changes this mindset completely. Thus, some case managers felt that under WIA 

they were taking much more time with each client, and thereby came to understand the 

client’s training needs and pre-existing skills and abilities much more completely. On the 

other hand, they often needed to overcome customers’ mistaken assumption that WIA, 

like JTPA, was “a training program” and that all customers would automatically be 

approved for training.

More generally, even grantees that had prior experience with vouchers, such as 

Baltimore, noted that staff training and capacity building needed to be ongoing efforts if 

the intent of WIA to empower customers was to be fully realized. Moreover, nearly all 

grantees found themselves far from having in place the informational infrastructure that 

the consumer report system requires, as a subsequent chapter will describe.

Overall WIA Readiness

Providing training through ITAs in a manner that is consistent with WIA requires 

more than developing ITA and ETP processes and procedures. On the contrary, ITAs 

need to be delivered as part of a comprehensive system for delivering employment and 

training services to a broad spectrum of adults and dislocated workers. This requirement 

entails establishing a One-Stop service delivery system, including the articulation of well-
II-5

developed self-service and staff-assisted core services and intensive services. In other 

words, in order for the ITA/ETP grantees to be effective in carrying out their grant 

obligations, they of necessity need to be operating within the context of a much more 

complex network of partners and services.

The level of WIA readiness varied substantially in the states and local areas that we 

visited, and this variation influenced to some degree how successful the grantees were in 

establishing their ITA/ETP systems by the time of our first site visits. Some grantees 

benefited greatly because the local area we studied or the state of which it was a part had 

long anticipated some of the changes required by WIA and had moved to develop a OneStop delivery system well before WIA was enacted. For example, One-Stop Centers had 

been long established and were functioning quite smoothly in Texas quite a few years 

before our site visit occurred. Their development came about as a result of the Texas 

Workforce and Economic Competitiveness Act of 1993, which mandated the 

establishment of Career Centers that were to include the participation of JTPA, 

Employment Services, Unemployment Insurance, and various education programs. 

According to the legislation, each center was to provide labor market information, 

common intake and eligibility determination for all local workforce development 

programs and services, the independent assessment of individuals’ needs and the 

development of individual service strategies, coordinated case management and 

counseling services, supportive services, and the use of individual referral for basic 

education and classroom occupational skills training. As a result of this head start, by the 

time the grant solicitation was announced, Texas had established over one hundred local 

Career Centers, of which 50 were characterized as WIA full-service centers.

In at least this one case, One-Stop service systems were to some degree homegrown and sprung from strong state-level initiatives. In our other case-study sites, 

however, One-Stop system building generally only began when the state was awarded a 

One-Stop implementation grant expressly for this purpose. These grants—which were 

awarded by DOL to all 50 states over a period of years from the mid- to late-1990s—

provided much needed financial resources that states and local areas used to modify 

infrastructure, purchase new equipment, and develop and support self-service resources 

and tools. Similarly, the national network of support that developed around One-Stop 

system-building provided a fertile ground for the incubation of new ideas and the 

dissemination of information about promising approaches and best practices. Indeed, 
II-6

across all the states that we studied, the One-Stop implementation grants, and the DOL 

vision that they represented, constituted a critical formative influence.

That uniform advantage notwithstanding, some states were clearly further along in 

the entire process of WIA implementation than others. A few of the states covered by the 

ITA/ETP demonstration (i.e., Texas, Indiana, and Pennsylvania) had applied to be WIA 

“early implementers,” which means that they were attempting to make the transition to 

WIA before the required start date of July 1, 2000. Some others had not applied for early 

implementation status, but nonetheless were also far along in the ir WIA transition 

process. As such, they had their state and local boards in place, had One-Stop systems in 

place, and, in general, had established necessary and relevant workforce policies and 

procedures. These states and the local areas that they represented were able to move 

quickly to establish their ITA/ETP systems, as was apparent when we first visited them in 

the summer and fall of the year 2000.

By contrast, other states were less ready with respect to the essential elements of 

WIA, and it typically slowed their ITA/ETP system development substantially. For 

example, one state was going through a somewhat difficult reorganization of its local 

areas at about the time the grant solicitation was announced. The controversy and 

disruption that this caused delayed One-Stop system building in the state such that no 

full-service centers had yet been chartered in the local area that we were going to visit as 

of the late summer of 2000, and virtually no one had yet been issued an ITA. 

In another example, one local area itself was substantially far along in making the 

transition to WIA at the time the ITA/ETP grants were awarded and in fact had been 

designated as an early implementer under WIA. By contrast, during this same time, the 

state was undergoing some major revisions to its WIA State Plan, including a 

reconsideration of the definitions of the three service levels and the sequence of services, 

a development that was hampering the local area’s efforts to finalize its ITA policies and 

procedures. 

GRANT PLANS AND GRANT IMPLEMENTATION

All of the ITA/ETP grantees are ultimately striving to obtain the same objectives—

well-developed procedures for issuing ITAs, a comprehensive and readily accessible 

consumer report system, and a mechanism for tracking the obligation and expenditures 

implied by issuing vouchers. That said, some grantees were further along than others in 

establishing elements of these systems by the time the grants were issued, partly as a 
II-7

function of their prior experience with vouchers and overall state of WIA readiness. 

Largely for this reason, they have identified different specific objectives in their grant 

plans and are consequently planning on using their grant funds in divergent ways. We 

identify some of these differences in Exhibit II-1, along with an indication of how 

progress towards grant implementation has proceeded to date.

As a glance at the table suggests, grantees have identified quite a wide variety of 

grant objectives. These range from the very broad, such as to further the development of 

ITA policies and ETP systems (several states), to the very specific, such as to develop the 

NC STARS system (North Carolina) or develop a code of ethics for vendors 

(Pennsylvania). In general, grantees that specified broader goals were not as far along in 

ITA/ETP system development at the time their grant proposals were prepared. By 

contrast, those that specified narrower goals had many elements of their systems already 

in place and were looking to enhance or refine them in some way.

Grant objectives can also be categorized with respect to their major area of focus. 

Along these lines, the most common cluster of objectives related to grantees’ efforts to 

build electronic consumer report systems. It is widely recognized that assembling 

performance information about each program for which vendors are applying for 

eligibility and developing a user-friendly computer interface by which prospective 

trainees can access that information are mammoth and costly undertakings. In 

recognition of this, ten of the thirteen grantees specified grant objectives that related in 

some respect to building or enhancing their consumer report system. In some cases, this 

represented an effort on the part of state grantees (or state partners of local-area grantees) 

to build a major part of their statewide CRS. The grants of Indianapolis, Georgia, 

Missouri, Nebraska, North Carolina, and Pennsylvania can be classified in this way, with 

some being much more specific about the system they were building than others were. 

By contrast, several local-area grantees, including Baltimore, SELACO, and Southwest 

Connecticut, were interested in building a local CRS, either as a supplement to the state’s 

emerging system (Baltimore) or as a temporary substitute (SELACO, Southwest 

Connecticut) in recognition of the fact that the states’ systems would not be operational 

for quite some time. As a further adjunct to the CRS, two grantees (Missouri and a localarea partner working in conjunction with Pennsylvania) are exploring the possibility of 

establishing a customer messaging system, whereby trainees could post comments about 

the quality of the training they are undertaking.
II-8

The next largest cluster of objectives, articulated by eight grantees, related to 

capacity building, typically for staff. As with the group above, the grantees in this 

category varied with respect to the specifics of what they were trying to accomplish. For 

example, Baltimore was interested in hiring experts in assessment and counseling, one for 

each of its several One-Stop Centers, to work with customers and case managers to 

ensure that customers had the best information possible concerning their skills and other 

attributes so that they could make wise decisions about suitable programs of study. 

SELACO had a similar objective but a markedly different approach. This grantee was 

intending to use its grant funds to develop and refine the curriculum for a two-week 

group workshop that all prospective trainees would be expected to attend. The objectives 

of the workshop were to enable customers to support and assist each other through the 

process of making training choices, benefit from each other’s experiences and peer 

support, and develop teamwork skills through this “task team” approach. Other grantees 

focused more traditionally on developing and delivering curricula for staff training 

related to ITA or ETP issues. Although this usually was intended to take the form of 

workshops or conferences for staff, some (Missouri and Pennsylvania) were interested in 

developing web-based staff training materials or modules.

The third largest category included six grantees that identified an interest in 

developing or testing ITA policies. Again, the specifics varied. One grantee 

(Indianapolis) is working in conjunction with several other local areas in the state to test 

alternative ITA polices, as a way of gathering information about which ones might be 

most effective. One of the local areas partnering with Ohio will administer an 

“environmental scan,” again with an eye to learning about, and learning from, variation 

that is naturally occurring across local areas. 

Macomb-St. Clair has a different approach to regional variation. This grantee is 

concerned (as are many other local areas around the country) about the confusion and 

possible unwanted competition among local areas that could ensue if each local area 

within a regional labor market adopted different ITA policies, such as with respect to 

caps on the duration or costs of training that would be funded or occupations considered 

to be in demand. If there were such variation, it is feared, customers could play off one 

local area against the others, or shop around for “the best deal.” To circumvent such 

difficulties the seven local areas that make up the Southeast Michigan Workforce Agency 

Coalition (SEMWAC) elected Macomb-St. Clair to spearhead an effort to develop 

uniform regional ITA policies and procedures. As part of its grant activities, then, this 
II-9

grantee hired a consultant to facilitate a workgroup of SEMWAC members that 

discussed: what funding streams should use the ITA process, what ITAs can be used to 

fund, how demand occupations should be defined, what funding or duration caps should 

be imposed, payment structures and processes, how ITAs should be coordinated with 

funds from other sources (e.g., Pell grants), and how trainees’ progress while in training 

should be tracked. It also is discussing developing a regional approval process for 

vendors submitting eligibility applications, so that a vendor would not have one of its 

programs approved by one local area but rejected by a neighboring one. 

In another example of how grant funds are being used, three grantees are 

attempting to develop software to facilitate the tracking of ITAs and ITA expenditures. 

In some cases, the software will enable customers to track their own balances (Missouri) 

and in others it is intended to be of primary benefit to the workforce area’s fiscal staff and 

case managers (Baltimore and Texas). In Texas, one local area (Golden Crescent) took 

the lead in developing ASSET, which will be used by each local area in the state to track 

ITA budget amounts and expenditures, average costs per student, training courses being 

accessed, and ITA completions. 

Three grantees (Texas, Pennsylvania, and Ohio) are using their grant funds to 

automate the vendor application process. These areas have realized that taking and 

processing paper applications is enormously time consuming and burdensome to staff. 

By automating the process, they anticipate realizing substantial resource savings.

Finally, a number of grantees have specified objectives that are quite unique and do 

not readily fit into any of the above categories. For example, Metro Portland sees that 

synergies can be realized between ITAs and Individual Learning Accounts and is using 

some of its grant funds to recruit employers to participate in its Learning Accounts 

program. One of the local partners participating with Ohio will be testing alternative ITA 

payment mechanisms (e.g., vouchers, smart cards), and a local area participating with 

Pennsylvania will be developing a code of ethics for vendors. Other areas in 

Pennsylvania will be exploring the feasibility of integrating employers’ in-house training 

into the ETP system and developing a system to pool requests for training from different 

social service agencies so that better rates from vendors can be negotiated.

This range of variation clearly speaks to the difficulty and complexity of 

developing ITA procedures and ETP and CRS resources, and the large number of distinct 

activities that must be accomplished and coordinated. In light of this, several grantees 
II-10

noted how fortunate they consider themselves to be in having been selected to participate 

in this demonstration, as it has provided them with access to special funds for system 

development that otherwise would have needed to come from their regular WIA formula 

allocation.

SUMMARY

The above review suggests that the grantees that were chosen to participate in the 

ITA/ETP demonstration generally had moved firmly away from contracted class-size 

training even before WIA was enacted. Most even had substantial prior experience with 

using vouchers, either as a CMA Demonstration grantee or otherwise. Due to their 

having received DOL One-Stop implementation grants during the mid- to late-1990s, 

almost all also had made substantial progress in having built the One-Stop systems that 

WIA requires. 

These facts made their transition to the use of ITAs much easier than it otherwise 

might have been. Thus, some of our respondents noted that case managers had 

previously adopted a “coaching” approach to working with their customers and that 

customers were encouraged to exercise individual choice in choosing programs of study 

and vendors. Some sites had even begun to assemble list of vendors, with information 

about programs offered and the duration of training and its costs, as a resource for 

potential trainees to use in making their decisions.

This prior progress notwithstanding, the transition to the use of ITAs was not 

trouble free. The most glaring problem that sites experienced was that performance 

information on vendors, consistent with the intent of the legislation, was almost wholly 

absent. Thus, substantial new work needed to be accomplished to build consumer report 

systems, as a subsequent chapter of this report will describe. Additionally, because 

training is not assumed to be the appropriate course for all adults and dislocated workers 

registered in WIA, as it might have been under JTPA, case managers in some cases need 

to change customers’ expectations.

When we examined their grant plans, grantees identified a wide variety of ways in 

which they would be using their grant funds to help facilitate these changes. These plans 

varied in their specificity, with more narrowly focused grant plans typically articulated by 

grantees that had substantial prior experience with vouchers and who were at more 

advanced stages of WIA implementation. Most common were plans to use funds to help 

build consumer report systems. Other key objectives articulated by the grantees were to 
II-11

use funds for staff training or other capacity building, developing or testing ITA policies, 

and building automated vendor application processes, among others. As of the writing of 

this Interim Report, it is too soon to assess the success with which grant funds were used 

and what was actually accomplished.
Exhibit II-1

Grant Objectives, Planned Expenditures, and Progress to Date

Grantee Primary Objectives of Grant Progress at Time of Site Visit Budget

Grantees that are Local Areas

Baltimore 

Office of 

Employment 

Development

1) Develop a local supplement to the 

state consumer report system, with 

information of local relevance.

2) Strengthen the assessment process 

by hiring an assessment specialist for 

each One-Stop Center.

3) Upgrade fiscal tracking system to 

track voucher obligations and 

expenditures.

1) Given the local job market, has had difficulty 

hiring a consumer reports specialist, which is 

delaying its development of the local consumer 

report system.

2) Has had difficulty hiring all the assessment 

specialists that it intended, but has compensated by 

having those that were hired rotate across Centers.

3) Has purchased the fiscal tracking system.

$500,000. Major line items are:

n Personnel and fringes $424,500

(career counselors, consumer reports 

specialist, data base manager)

n Equipment $25,500

(for fiscal and customer tracking 

system and assessment tools)

Indianapolis 

PIC

1) Implement an enhanced consumer 

reporting system.

2) Explore alternative local ITA 

policies (each local area will try an 

alternative).

3) Develop a staff training curriculum.

4) Share results nationally and 

regionally.

5) Collect information on customer 

satisfaction.

1) Implementation of enhanced CRS is proceeding 

but has been delayed somewhat.

2) Implementation of local policies is proceeding.

3) Staff training tools have been developed.

4) Presentations have been made to share results.

5) Customer satisfaction data are being compiled.

$497,500. Major line items are:

n Personnel and fringes $330,000

n Supplies $52,000

n ITA vouchers $30,000

(to provide ITAs to customers who 

are deemed to be making poor 

training choices)

n Consultant $38,000

(develop materials for staff training)

Macomb/

St Clair 

Workforce 

Development 

Board

1) Establish agreement regarding ITA 

and ETP policies and systems among 

the seven local workforce areas in 

southeastern MI.

2) Develop a computerized 

information system, for use in the 

region.

1) Groundwork has been laid in identifying 

regional variation, but agreement on common 

policies has not yet been reached.

2) The development of the local information 

system is in abeyance, because rapid progress on 

the state system may have obviated its need.

$431,665. Major line items are:

n Personnel and fringes $197,400

n Contractual $209,800

(responsible for coordination, final 

product development, staff training, 

computer design)
Exhibit II-1 (continued)

Grantee Primary Objectives of Grant Progress at Time of Site Visit Budget

Grantees that are Local Areas

Metro 

Portland 

worksystems

1) Develop uniform guidelines and 

policies and provide TA to the One-Stop 

Centers in worksystems.

2) Develop a cost-benefit matrix for use 

by counselors, and conduct ROI 

analysis.

3) Incubate Individual Learning 

Accounts with local employers.

1) Has made substantial progress in developing 

uniform policies and providing TA to Centers.

2) Abandoned plans for cost-benefit matrix and 

ROI analysis.

3) Has had success in incubating Learning 

Accounts; thus far, four employers are 

participating.

$500,000. Major line items are:

n Personnel and fringes $97,000

(project lead, project assistant)

n Contractual $181,600

(develop consumer report system, 

develop cost-benefit matrix, conduct 

ROI analysis)

n Training Stipends $100,000

Southeast 

Los Angeles 

County 

(SELACO)

1) Modify a curriculum used in CMA in 

which prospective ITA holders 

participate in a 2-week group workshop.

2) Develop a matrix with information on 

local areas vendor performance (to be 

used given that state CRS is delayed).

1) The curriculum has been developed and three 

group workshops have been conducted; however, 

there have thus far been fewer trainees than 

expected.

2) Have developed the local area vendor 

performance matrix.

$500,000. Major line items are:

n Personnel and fringes $394,400

(project coordinator, 2.5 placement 

specialists, evaluator, computer 

support)

n M&S $97,800

(occupancy, equipment, supplies)

Southwest 

CT (The 

Workplace)

1) Create local eligible provider list, to 

be used given that state CRS is not yet 

ready.

2) Develop ITA policies and processes.

3) Market to vendors; review 

applications.

1) Grappling with the usual difficulties in 

measuring vendor performance.

2) Have made substantial progress in developing 

ITA policies and processes.

3) Have devoted substantial effort to reviewing 

vendor applications for eligibility.

$500,000. Major line items are:

n Personnel and fringes $405,500

(2 career counselors, project 

manager, service provider monitor)

n Contractual $38,5000

(database software, capacity 

building)

Grantees that are States

Georgia 

Department 

of Labor

1) Develop an ETP list and CRS and 

integrate with state MIS.

2) Develop state and model local ITA 

policies based on CMA model used in 

metro Atlanta; adapt and test in a rural 

area (e.g., distance learning).

1) Development of the state ETP list and CRS is 

underway.

2) State policies, a draft technical assistance guide, 

and model local policies have been prepared.

$500,000. Major line items are:

n Personnel and fringes $203,000

(project manager, tech support, 

survey specialist, training, fiscal)

n Contractual $176,000

(data base systems management, 

staff training specialist)

n Equipment $39,500

(mainframe upgrade, demo kiosks)
Exhibit II-1 (continued)

Grantee Primary Objectives of Grant Progress at Time of Site Visit Budget

Grantees that are States

Missouri 

Division of 

Workforce 

Development

1) Develop and implement the consumer 

report system.

2) Add a “comparative shopping cart” 

feature to existing state ETP list.

3) Create a system to allow customers to 

track ITA balances.

4) Develop a live web-based staff 

training system. 

6) Develop a web-based customer 

feedback system

Work is proceeding on all components of the 

state’s grant plan. 

$500,000. Major line items are:

n Personnel and fringes $60,000

n Contractual $420,000

(enhance web consumer report 

system, develop tracking system, 

develop staff web-based training 

and web-based satisfaction survey) 

Nebraska 

Department of 

Labor

1) Build a comprehensive consumer 

report system and ITA policies. 

2) Develop high quality LMI. 

3) Develop ETP list in Spanish. 

4) Provide staff training.

1) Work is proceeding on building the CRS and 

ITA policies. 

2) Efforts to develop LMI are proceeding.

3) Efforts to develop Spanish-language ETP 

systems have been been on hold.

4) Some staff training has occurred and additional 

efforts are planned.

$444,000. Major line items are:

n Personnel and fringes $186,000

n Contractual $170,000

n Training stipends $50,000

North Carolina 

Workforce 

Development 

Commission

The major objective was to create NC 

STARS, a fully automated system with 

modules that include: 

1) An ETP database, allowing for 

vendors to submit online applications 

and with programs crosswalked with 

occupations, 

2) A provider approval system showing 

programs approved by each local area, 

3) A Consumer Report System w/ 

vendor performance data, 

4) Info from customer feedback.

Additionally, this grantee wants to:

5) Use 3-5 local areas to pilot different 

ITA policies and procedures.

Although refining NC STARS is viewed as an 

ongoing process, substantial progress has been 

made to date in the development of this system

1) The ETP module is largely complete, 

2) The local approval system has been developed 

and is being refined, 

3) The vendor performance subsystem has been 

developed, though performance data are sparse, 

4) Customers can provide feedback to the 

webmaster. 

5) The grantee abandoned plans to pilot different 

ITA policies and procedures.

$500,000. Major line items are:

n Personnel and fringes $ 72,000

n Contractual $360,000

(system development)
Exhibit II-1 (continued)

Grantee Primary Objectives of Grant Progress at Time of Site Visit Budget

Grantees that are States

Ohio 

Bureau of 

Employment 

Services

1) Provide “triage” training for staff.

2) Conduct public forums.

3) Test various ITA payment 

mechanisms.

4) Develop electronic vendor 

application process.

5) Conduct an environmental scan to 

poll local areas on their policies.

1) Training is underway. 

2) Public forms should be conducted on schedule.

3) Planning for alternative payments are underway 

4) Electronic application has been delayed until 

year 2.

5) Plans for scan are underway but are meeting 

with some local area resistance.

$500,000. Major line items are:

n Personnel and fringes $342,000

(at state: project coordinator; at local 

level: project director, two career 

planners, clerical)

n Consultants $30,000

(technology consultant, survey 

consultant)

Pennsylvania 

Department 

of Labor and 

Industry

1) Develop a web-based statewide 

ETP list and a consumer report 

system, as part of a larger One-Stop 

operating system.

2) Provide training to staff.

3) Develop an ITA manual for participants and a code of ethics for 

vendors.

4) Develop a system to include 

employer in-house training as part of 

the ITA system. 

5) Allow trainees to post messages on 

the web about their training.

6) Develop a system to allow a 

variety of organizations seeking 

training services to pool their 

requests, as a way of negotiating 

better rates.

1) Electronic components are under development. 

The ETP list was fully electronic.

2) Training has been provided; on-line resources 

are available. 

3) Code of ethics is approaching draft form.

4) Development of system to include in-house 

employer training is underway. 

5) Limited progress on messaging system thus far.

6) Development of system to allow seekers of 

training to pool requests is underway.

$500,000. Major line items are:

n Personnel and fringes $153,000

(staff to develop policies for capacity 

building, provide grant oversight)

n Contractual $333,000

(for 5 LWIA pilot sites; vendor to 

develop online vendor application 

system)

Texas 

Workforce 

Commission

1) Enhance and automate the State 

Training Provider Certification 

System, to allow for automation of 

applications for eligibility.

2) Develop an automated system to 

track ITAs and expenditures.

1) A prototype of TPCS has been developed. 

2) A prototype of the tracking system has been 

developed.

$500,000. Major line items are:

n Personnel and fringes $142,000

n Contractual $309,500

(for TPCS: $215,500; for ITA 

tracking: $94,000) 

_____________

Note: Objectives of the grant are as specified in the grant application and updated as of the site visit. Progress in carrying out the grant reflects status at the time site visits were conducted. 

The budget column identifies the budgeted request as of the grant application, with a breakdown of how the bulk of those funds were expected to be spent.
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III-1

III. CUSTOMERS’ USE OF THE ITA

WIA has set forth a new vision for services to customers. Instead of strictly 

targeting dislocated and disadvantaged workers as JTPA did, the new law seeks to make 

employment and training services available to the entire labor force. Moreover, unlike 

JTPA, where training was the expected service for most participants, WIA permits 

training only if job seekers are unsuccessful in the core and intensive services. This 

movement through the levels of service is substantially regulated by federal, state, and 

local policies. However, once an individual is approved for training, a less regulated 

more market-based approach is promoted, in that WIA participants become customers 

who should have a great deal of latitude in selecting the training program and vendor that 

they think will best suit their needs. This choice is to be supported by staff resources and 

information on labor markets and vendor performance. 

This chapter discusses how these processes operate in the ITA/ETP sites we visited. 

It begins with a discussion of the emphasis that sites placed on training in general, and 

ITAs in particular. We use this as a departure point to explore how customers actually 

access and use ITAs at the local level. We delineate the requirements governing the path 

and actual services that job seekers use during core and intensive services on their way to 

training and an ITA, and detail the ITA decision-making process of choosing training 

occupations and vendors. The chapter then considers the services that One-Stop centers 

provide to ITA holders during and after training, and looks at how One-Stop centers 

coordinate the ITA with funding from other sources. 

In examining these issues, we note that, although WIA provides substantial 

opportunity for states to develop rules and policies affecting the use of ITAs, state 

administrative agencies generally defer to LWIAs almost entirely on customer-service 

issues. This approach reflects a deliberate state deference to local responsibility for the 

shape and conduct of participant services. 

EMPHASIS ON TRAINING AND ITAS

Customer access to and use of ITAs is determined by a number of important 

systematic factors that affect the emphasis that Local Boards in the demonstration sites 

place on training in general and ITAs in particular. We look at this issue through the 

prism of local policies and funding levels for training and explore how the local sites 
III-2

balance ITAs against other forms of training. Exhibit III-1 summarizes some of our 

findings.

Emphasis on Training in General

Whether a local site has a strong interest in raising the skill levels of a small 

number of people through training or assisting a large number through job search and 

other less costly services reflects a long-running debate in the employment and training 

community. The lack of consensus on this issue was reflected as well among the sites we 

visited. Thus, some avowed the intent to continue high levels of funding for training, and 

expected to spend 50% or more of their total WIA allocation for adults and dislocated 

workers for this purpose. Others anticipate much more modest funding levels, with some 

anticipating spending less than 20% of their funds for training. 

Among the factors that entered into their decision on this issue was how to balance 

WIA’s emphasis on using training as a “last resort,” with the sites’ traditional focus on 

providing job training to meet the needs of the disadvantaged. At the one extreme, four 

of the state grantees indicated that they are actively pursuing a work-first policy, or are 

otherwise emphasizing core and intensive services. In those states, the local response is 

consistent with the state emphasis, and many fewer people are being placed in training 

than was the case under JTPA. By contrast, other states and local areas maintain a strong 

interest in training. They are able to take customers with an evident need for 

occupational skills and move them promptly through core and intensive services and into 

training. These sites are planning to train about as many participants as they did under 

JTPA. Southwest Connecticut, for example, indicated that it has a strong commitment to 

training, because training is the service that its participants have always needed. 

Baltimore and metro Portland also sought to keep their levels of training high, based on 

what they saw as the primary needs of their communities. 

The availability of funds for training was another chief consideration. Many of our 

local sites reported that they have much less money to spend on training than they once 

did, in part because of the WIA requirement to establish a One-Stop system and three 

levels of service, including core services for the entire labor force. Given this 

requirement, several states noted that there was not enough money to provide good 

quality core and intensive services and still have funds available for training. In the case 

of Texas, this funding limitation disappointed local officials who felt that the higher level 

of training under JTPA made their program successful. For example, Golden Crescent 

staff indicated that, after paying for a One-Stop infrastructure
III-3

Exhibit III-1

Emphasis on ITA and Other Training

Local Area (Grantee) Emphasis on Training Use of Non-ITA Training

Baltimore OED Planned 50% of WIA funds 

to be spent on training

Strong interest in OJT, classsize, and customized training

Indianapolis PIC Trying to maintain level of 

training under JTPA 

Very little OJT or other 

contract training

Tecumseh Area Partnership 

(Indianapolis PIC)

Planned 40% of WIA funds 

to be spent on training

Very little OJT or other 

contract training

Macomb/St. Clair Workforce 

Development Board

Planned one-third of WIA 

funds to be spent on training

Some customized training 

and OJT are planned

Metro Portland worksystems Trying to maintain level of 

training under JTPA 

Emphasis on literacy and 

computer skills in intensive 

services 

Southeast Los Angeles 

County 

Training expected to be lower 

than under JTPA because of 

strong labor market

Extensive use of OJT and 

customized training

Southwest Connecticut Strong commitment to 

training, although fears 

resources will be limited

Very little use of OJT

Areas covered by the Metro 

Atlanta Regional Comm. 

(Georgia Dept of Labor)

Each One-Stop center has a 

training budget

Some class-size contracts for 

certain high volume 

occupations, retaining 

customer choice 

West Central/Sedalia (MO 

Workforce Development)

Strong emphasis on core and 

intensive

Some use of OJT and 

customized training

Greater Lincoln (Nebraska 

Dept of Labor

Planned 50% of WIA funds 

to be spent on training

ITA is sole source of training

Capital Area/Raleigh (North 

Carolina Workforce 

Development)

Strong emphasis on core and 

intensive

No plans to use OJT or 

customized training. 

Cincinnati (Ohio Bureau of 

Employment Services)

Less WIA-funded training 

expected than under JTPA, 

but more training overall 

because of One-Stop partners

Reduced use of OJT under 

WIA

Emphasis on literacy and 

computer skills in intensive 

services 
III-4

Exhibit III-1 (concluded)

Local Area (Grantee) Emphasis on Training Use of Non-ITA Training

Three Rivers Workforce 

Board (Pennsylvania Dept of 

Labor and Industry) 

Statewide work-first 

emphasis and limited 

resources; reduced emphasis 

on training

Some class-size contracts for 

certain high volume 

occupations while retaining 

customer choice; very little 

OJT

Golden Crescent (Texas 

Workforce Commission)

Limited resources; reduced 

emphasis on training

Very little OJT; emphasis on 

literacy and computer skills in 

intensive services

Heart of Texas (Texas 

Workforce Commission)

Limited resources; reduced 

emphasis on training

Very little OJT; emphasis on 

literacy and computer skills in 

intensive services

________________

Note: The first column lists the local area we visited (with the name of the ITA/ETP grantee in 

parentheses, if different from the local area).

and computer systems, little was left for training. Officials in another state pointed out 

that establishing the One-Stop system imposes a substantial financial burden on the 

LWIAs. A local area’s executive director confirmed the state’s observation, noting that 

maintaining the One-Stop system drains WIA funds because other partners are not 

contributing a fair share of the infrastructure costs. By contrast, other sites are able to 

maintain ample funds for training even after they had incurred One-Stop costs, partly 

because of deliberate decisions about their local priorities and their prior progress in OneStop system building (e.g., using DOL One-Stop implementation funds), and because 

other partners (such as the Employment Service) are contributing substantially to funding 

core services. Thus, Baltimore and the Greater Lincoln LWIAs are planning to spend 

50% of their funds on training, while Indianapolis has earmarked 40% for this purpose. 

Another factor that seemed to be important and led to a decreased emphasis on 

training in many sites was the strong economy. LWIAs that see employers as their 

primary customers want to get jobseekers employed as quickly as possible. These 

LWIAs frequently have jobs readily available that can be filled with no training or with 

in-house skill building on some basic business software applications through intensive 

services. Similarly, the demand for workers is so strong in its labor market that the Three 

Rivers Local Board, even when it provides training, is looking for very short-term 

interventions. Tight labor markets also reduce the demand for training from job seekers. 
III-5

For example, SELACO, which intended to spend as much on training in its first year of 

WIA operations as it did under JTPA, finds that it is spending less than expected because 

of low demand for training by job seekers.

ITA versus non-ITA Training

Once local areas make a commitment to training as a service, they still have some 

options to use other forms of training besides the ITA. WIA (Section 134d4G) permits 

LWIAs to use customized training and on-the-job-training (OJT) and otherwise to 

establish contracts for training if there is an insufficient number of providers to establish 

the competitive training market that an ITA system envisions, or to fund communitybased or other private organizations to serve participants with multiple barriers to 

employment.1 

In general, most of the demonstration sites made little use of these contractual 

training alternatives. A number of state respondents reported that OJTs, which had been 

sharply regulated since the 1992 JTPA Amendments, were not commonly used in many 

local areas in their states. Nor was there much use of customized or other forms of 

contract training. Only two local sites stand out as exceptions. Baltimore noted that a 

substantial portion of its funds are earmarked for non-ITA training, including employerbased customized training, OJT, and contract training for participants with barriers to 

employment. SELACO reported that it also planned for a substantial amount of contract 

training (although the strong economy has reduced the demand for its contract training as 

well as for ITAs). These sites felt that customized training had an important role to play 

because its unit cost was often substantially cheaper than an ITA and because the training 

could be easily tailored to meet the needs of trainees of particular types.

ESTABLISHING CUSTOMER ACCESS TO ITAS

Since WIA limits training to those who are unable to find a job that will provide for 

self-sufficiency, customers who receive an ITA must have gone through at least one core 

and intensive service. The local sites vary a good deal in the requirements establishing 

eligibility, movement through the three service levels, and the methods of delivering 

services. In many cases, what happens to a participant in these earlier levels of service 

has a direct bearing on the course of the individual’s ITA.

 

1 However, even providers funded through contracts must meet performance requirements 

established by the Local Board.
III-6

Customer Flow through Core Services

All the sites follow the statutory requirement that a customer must receive at least 

one core service before moving on to intensive services. Some of those sites, however, 

either specify a particular core service that a customer must use or establish their process 

so that a customer would almost certainly pass through that service. There was quite a bit 

of variation in what those services consist of and how comprehensive they are. For 

example, in Greater Lincoln, where ITAs are quite accessible, the core service could be 

the One-Stop orientation. In another, a customer must go through only the initial 

assessment. In Baltimore, a customer would typically begin by registering with the 

Employment Service job matching system. If a match occurs, the customer would 

receive a referral, but otherwise is scheduled to meet with a case manager who would 

help the customer to refine the job matching criteria and use self-assessment tools. At the 

other end of the spectrum, one site requires multiple core services and is very specific 

about their content. To advance to intensive services, customers generally must:

• Attend the One-Stop orientation.

• Take the core assessment.

• Register with the Employment Service job matching system

• Attend two job search workshops.

• Apply for six jobs without an interview or attend three interviews without 

receiving a job offer.

Needless to say, this site does not send a high percentage of people who start in core 

services on to training. 

Most of the sites we visited applied the same requirements for core services to 

adults and dislocated workers. As the basis for this, a case manager at one of the Atlanta 

Regional local sites did not believe that there were sharp distinctions between adults, who 

were mostly low-income or on welfare, and dislocated workers. She sees each group as 

overlapping on a continuum, with some low-income adults as vocationally ready as some 

lower-skilled dislocated workers. The major difference she noted was that low-income 

customers often required somewhat more staff resources because they tended to be less 

sure of what they wanted to do. 

On the other hand, a few sites had a completely different approach for each group. 

At Southwest Connecticut, for example, dislocated workers are ushered into the resource 

room and encouraged to sign up for job search workshops; at the end of the workshop 

series, they conduct a self-assessment and work on a resume and only then will meet a 
III-7

case manager in a one-on-one session. By contrast, low-income adults are encouraged to 

sign up for membership in the One-Stop center and meet with the membership 

coordinator who probes for basic information, including whether the customer has an 

interest in training. Those who have such an interest and meet other priority-group 

criteria meet with a case manager that first day, so that counseling and basic skills and 

other assessments can begin. The local area staff had previously found that, without this 

extra staff assistance, low-income adults and welfare recipients were not successfully 

navigating through the One-Stop’s self-service activities.

Regardless of the general approach, however, all the demonstration sites, including 

those that had a more rigorous set of required core services, indicated that guidelines 

were not meant to be followed rigidly. In fact, all the sites emphasized their flexibility 

and that they treated all customers individually according to their needs. Thus, staff 

endeavor to quickly identify people who were demonstrably in need of more intensive 

services or those who may have been referred by another One-Stop partner and could 

assert or present evidence that they had used core services elsewhere. 

Because of this flexibility, there was extremely wide variation in the length of time 

that customers would spend in core services, even within a given center. Thus, many of 

our respondents were quick to note that customers who were evidently in need of more 

staff assistance could move from core to intensive services very quickly, potentially even 

within a single day. On the other hand, customers who appeared to have marketable 

skills might spend several weeks in core services, or even longer, while engaged in job 

search.

Clearly, then, the staff’s ability to identify a low-skill customer for whom job 

search is likely to be futile is critical to shortening the period in core services. The 

customers’ own motivations and preferences can be important as well. Thus, several case 

managers indicated that customers who knew they wanted and needed training could be 

moved through core services quite quickly. In one site, for example, where core and 

intensive combined ranged from three days to three weeks, the duration was largely 

determined by how quickly the customer wanted to schedule case management and 

counseling sessions.

This substantial within-site variation notwithstanding, site-to-site differences were 

also important, including each site’s general propensity to use training. As noted earlier 

in this chapter, some sites are deeply committed to providing more training to customers, 
III-8

and in these sites customers are moved along to intensive services more quickly than 

elsewhere, on average. By contrast, other sites are strongly committed to exhausting all 

possibilities that customers could be employable with their existing skill sets, leading to 

durations that are usually longer. For example, at one site we observed two dislocated 

workers who were still in core services after several weeks, even though they expressed a 

strong interest in computer-related training. Although these individuals were interested 

in training that would lead to careers that offered excellent employment prospects and 

high wages, this LWIA required customers to fully work through a job search before they 

would be determined eligible for an ITA. Paradoxically, in some sites with a strong 

commitment to training, discussions related to ITA decision-making, such as occupation 

or vendor choice, may occur during core services, having the effect of increasing the 

duration of core services (although they should reduce the amount of time for ITA 

decision-making). 

Another important element of each center’s own policies that to some degree was 

related to the average time that customers spent in core services was how much the center 

was inclined to emphasize self-service as opposed to staff-assisted core services. We 

observed two general approaches: sites that emphasize self-services and sites whose staff 

intervene with customers almost immediately. Among the sites that emphasize selfservices, participants enter a resource room to register with the Employment Service and 

use on-line job search systems and computerized assessment and resume tools. 

Typically, they use these tools on their own, and the principal staff function is to help 

people in their use. In these centers, staff move about the resource room to see if anyone 

is having trouble with the equipment or software or otherwise needs help, but otherwise 

let customers alone. As a consequence, in this and similar sites, many customers may 

have relatively little contact with staff, especially if they are familiar with computerized 

information tools or are otherwise computer-savvy. 

Some sites, on the other hand, use a staff-intervention approach, with case 

managers sometimes offering assistance as soon as a job seeker comes into the One-Stop 

center. In Cincinnati, a customer meets a staff member immediately and moves into 

some form of staff-assisted core services. In Baltimore, a series of staff members 

“facilitate” a customer’s use of core services. Many sites combine both approaches, as in 

the Atlanta Regional local areas. In their One-Stop centers, self-service was the norm 

after an orientation, but anyone requesting staff assistance was immediately assigned to a 

case manager.
III-9

Among those sites where the customer is already working with a staff member, it is 

easy to determine whether the core job search is unsuccessful. In sites where there may 

not be a staff member who is monitoring progress, One-Stop centers may require 

customers to document an unsuccessful job search, which might include a list of job 

contacts an Unemployment Insurance claimant may have submitted to support a 

continuing claim. 

Customer Flow through Intensive Services

In keeping with the legislation (WIA Section 134d3A), customers are eligible for 

intensive services only if they are unemployed and unable to obtain employment through 

core services or are employed but are in need of intensive services to attain selfsufficiency. All the One-Stop centers we visited follow these statutory requirements. 

With respect to those already employed, the law does not set a specific means test for self 

sufficiency, theoretically allowing LWIAs to provide intensive services to any adult. 

However, most Local Boards set their own definitions for employed adults at quite low 

levels, effectively barring services to those who are not low-income. The most common 

standard is the lower of the poverty level or 70% of the Lower Living Standard Income 

Level, which is the federal means test for low-income adult status. A few local areas peg 

their self-sufficiency level somewhat higher, such as at the Lower Living Standard 

Income Level, allowing more adults to qualify for these services. For dislocated workers 

a common standard is 100% of the worker’s wage at dislocation. Another Local Board, 

Three Rivers, sets self-sufficiency at 93% of the dislocation wage, a standard that 

excludes more dislocated workers. That board, however, was considering a substantial 

increase in the definition of adult self-sufficiency to equal a “living wage,” which might 

be in the $8-$10 range.

Closely linked to self-sufficiency is the legislation’s stipulation (WIA Section 

134d4E) that, within the adult program, priority for intensive and training services should 

be given to those who are low-income adults or are welfare recipients when funds are 

limited. Local Boards must establish their own priority policies. Most of our sites 

formally declared a funding shortage at the beginning of the program year to ensure 

priority for the economically disadvantaged. Several also adopted additional priority 

criteria. For example, the Missouri West Central local area gives higher priority to 

people with the greatest number of barriers to employment. One site uses a geographic 

emphasis, giving priority to residents of its Enterprise Zone. Four local sites make 
III-10

veterans a priority group. Another site establishes priority for those who lack any work 

experience, lack relevant work experience, or have the least education. 

Many local boards provide exemptions to their priority policies to permit intensive 

and training services to adults who are not low-income and may not fall into any of the 

other priority groups that were established. Thus, even where funding shortages were 

declared, case-managers are often authorized to exercise their discretion to approve 

intensive or training services for some participants outside the priority groups. Two other 

sites indicated that they did not face a funding shortage at the time of the site visit, so 

priority was not established for low-income or welfare adults. With so few customers 

unable to find employment through core services, they were able to train any individual 

who was otherwise eligible, despite their priority policy. 

With respect to the content of intensive services, all the local sites we visited 

require a full assessment and completion of an individual employment plan. Most also 

offer the normal menu of intensive services as specified in the legislation, including basic 

skills training, brush-up skills on computers and basic office software, as well as 

individualized job search assistance. But sites differ considerably in the way they 

implement their designs, often according to the emphasis they placed on training. 

In sites with less of an emphasis on training (see Exhibit III-1), job search is often 

the focal point. These sites tend to send only a small portion of their intensive-service 

participants on to training and then only after a period of concerted job searching. 

Among the common reasons given for this approach are to meet the demands of local 

employers, limited funding for training, and the statutory requirement that training occur 

only after intensive services are unsuccessful in helping the participant to find a job. In 

these sites, the assessment and individual employment plan focus on expanding the job 

search rather than increasing the customers’ skill level. In one site, for example, the first 

intensive service is a conversation between a case manager and participant to analyze 

why the job search in core services was unsuccessful. The customer then receives 

assessment and is routed into particular job search workshops to address any 

shortcomings of the earlier job search strategy. 

By contrast, in nearly half of the local sites a large percentage of participants in 

intensive services eventually go on to training. Consequently, in these sites intensive 

services revolve around planning for training, which in most cases is the ITA. The 

assessment and individual employment plan typically identify an appropriate training 
III-11

occupation and vendor. For example, in both Greater Lincoln and Greater Omaha the 

staff had already identified those people who needed and wanted training before moving 

them into intensive services. For such individuals, the assessment and individual 

employment plan developed as part of intensive services focus on training decisions. 

Similarly, in Allegheny County the individual employment plan identifies the skills and 

courses the customer needs to achieve a career goal. 

Still other sites have expanded the menu of intensive services considerably, at least 

partly to ensure that short-term skill building can be accomplished without the need for 

training services. For example, one site emphasizes how much richer its intensive 

services became when it brought basic skills, computer literacy, and common business 

software applications into its intensive service menu. These enriched services enable 

many customers to address their skill deficits and find a job within intensive services; 

thus, relatively few are going on to training. 

Movement from Intensive Services to Training and ITA

Most of the sites reported that they do not add any additional criteria to the basic 

statutory requirement that customers should only move to training if they are unable to 

find a self-sufficient job through intensive services and have the skills to succeed in 

training. Still, while not modifying the qualifying requirements, some sites interpret 

them very narrowly, making a very careful review for evidence that a customer has any 

transferable skills. For example, in one site staff indicated that they are cautious in 

approving training in order to avoid mistakes; thus, even though one-third of the local 

area’s budget had been set aside for training, only three customers (out of approximately 

75 enrollees) had been issued an ITA at the time of our site visit.

Other sites seem readier to move an individual to training, while still providing a 

rigorous set of intensive services. For example, in Southwest Connecticut the decision to 

train is made while the individual employment plan is being developed, but after efforts 

have been made to identify and address obstacles to employment such as poor 

interviewing skills or lack of good labor market information. 

CHOOSING TRAINING OCCUPATIONS AND VENDORS

Once customers have been determined eligible for training services, they confront a 

key issue in the ITA/ETP system: how One-Stop staff and procedures can help them 

make good choices. These choices need to be agreeable and beneficial to customers and 

contribute to the favorable outcomes for which Local Boards and states are held 
III-12

accountable. In this section, we explore the heart of the ITA system by discussing the 

resources and processes that LWIAs use to effectuate choice.2 We look at several models 

of customer choice, the processes used to make selections and approvals, and the impact 

that vendors have on decision-making. 

Types of Customer Choice

The essence of customer choice is present in all the sites we visited, in that 

customers are typically choosing occupations and vendors that they want. We saw no 

evidence that customers are being placed in classes contrary to their preferences because 

the LWIA had negotiated a contract and needed to fill training slots.3 These findings 

suggest that there has been substantial progress in the sites we visited in reaching one of 

the key statutory objectives of the ITA system. 

The real variation among sites occurs in the way choices are made rather than 

whether there is choice at all. To help explain these variations we have posited three 

models of customer choice that reflect the broad middle and the outer bounds of how 

decisions are made in the ITA system at the sites we visited.4 We call these variants

informed choice, directed choice, and free choice.

Informed Choice. In the informed choice model, which constitutes the broad 

middle ground, the One-Stop centers provide information and assistance and develop 

procedures that lead customers to make wise choices on their own. We found an 

overwhelming preference among the One-Stop centers we visited for this model. 

Throughout these sites, our respondents consistently described customers as making 

choices based on good labor market information, a realistic assessment of their abilities, 

and some knowledge of the training programs and their performance. Most of the key 

system components to support this type of decision-making are already present. All the 

states have labor market information systems available, typically allowing online access 

 

2 As we noted in our discussion of intensive services above, some of these decisions actually take 

place during intensive services.

3 Two sites in large metropolitan areas reported that they retained class-size contracts for certain 

occupations for use by ITA holders. Staff indicated that these contracts were for high volume training 

occupations such as certain computer network engineers or various medical specialists and technicians, and 

were only used for customers who clearly expressed a preference.

4 Our colleagues at Mathematica Policy Research developed these three models for the experimental 

evaluation of ITA outcomes described in Chapter I. 
III-13

in searchable formats. Assessments are required and conducted using the vocational 

counseling industry’s standard tools. Some local areas use certified counselors, either inhouse or under contract. In addition, information about the training programs and 

vendors comes from the eligible provider lists that are mostly now available online. Case 

managers also frequently supplement the information available from the ETP list with 

their personal knowledge of vendor capabilities.5 In general, we found that, when 

customers had good ideas based on sound labor market information, staff were likely to 

provide a wide scope for free choice. Overwhelmingly, then, our interviews and 

observations of counseling sessions suggested that the customer is the real decisionmaker. As one case manger in Southwest Connecticut noted, “We have to respect the 

customers’ knowledge of themselves (because, ultimately) they are the ones who have to 

show up (for the training).” 

Nonetheless, front-line staff play a key role in guiding or facilitating choices. Case 

managers consistently describe themselves as guides, facilitators, or information brokers, 

and one site even includes the term “facilitator” in all the job titles for its front-line staff. 

Case managers thus clearly play a pivotal role in ensuring that the customer’s choice is 

actually informed by good information. The role generally appears to be a real 

compromise between expertise and facilitation. One case manager in the Atlanta area 

describes this balancing role in working with a customer who may be making a poor 

decision as follows (below is a paraphrase): 

We work extensively with customers to persuade them about which vendor 

would be suitable, in terms of the curriculum, pedagogical approach, and the 

types of ancillary services available at the school. However, if a customer 

insists on choosing a particular vendor—even if we think there is a more 

suitable vendor—we normally approve the request, but remind the customer 

that there will be no second chance (at further training).

Consistent with the facilitative role, several sites substantially increased the level of 

responsibility for front-line staff when compared with their roles before a voucher system 

was introduced. Thus, for example, administrators in Baltimore noted that their front-line 

staff were no longer the “paper pushers” they had been under JTPA, but are now 

empowered to work with customers to respond to their unique needs.

 

5 At the time of the site visits, only two of the states had consumer report systems operational, with 

vendor performance information available. Thus, case managers’ knowledge of different vendors and their 

performance might have been used more heavily than might otherwise have been the case. 
III-14

Directed Choice. Directed choice provides the same types of labor market and 

vendor information to the customer, but in this model staff must work especially hard to 

ensure that the customer makes a decision that is heavily influenced by the staff’s 

professional judgment. Only two sites appear to be practicing directed choice for all their 

customers. In these sites, case managers try to control the terms of the decision-making 

to a greater degree than in the informed choice sites. Staff work to convince customers 

that their professional judgment is preferable to the vagaries of the customer’s less 

informed judgment. They may be very blunt in suggesting to their customers what 

program to select and where they should go to school. By way of justification, an 

administrator in one site noted that “people do not always know what is best for them.”

Under some circumstances a directed choice model is also used in centers that 

generally practice informed choice. For example, one case manager who worked mostly 

with current or former welfare recipients indicated that many of her customers did not 

readily understand how to use the decision-making tools or how to interpret their output, 

so she has to take a much more directive role than she otherwise would. Elsewhere, case 

managers often play a key role in dissuading customers from their choices when they 

come into the center with ill-informed training ideas—occupations with poor prospects 

for self-sufficiency or vendors ill-suited to their learning styles. The high level of staff 

intervention with such customers effectively reduces the scope of independent decisionmaking that is available to most others.

Free Choice. In a free choice model, customers can access labor market data, 

vendor information, and assessment tools at their discretion, but are generally left free to 

make their own training choices (so long as the program of study is for a demand 

occupation and the vendor is on the eligible provider list). While no sites use a standard 

free-choice model exclusively, it does occur quite frequently for customers who know 

exactly what they want before they come into the One-Stop center. These customers 

often have very specific training plans with an occupation and a vendor already picked 

out at the outset. Where the soundness of plans can be confirmed based on good labor 

market information, the vendor’s suitability, and a realistic assessment of the individual’s 

own capabilities, these customers typically get their choice with a minimum of staff 

intervention. 

Process Used in Making Choices

In addition to requiring assessment, providing access to labor market information, 

and offering professional guidance and facilitation by staff, many of the sites created 
III-15

processes that also help customers make a better-informed choice. Indeed, some of these 

processes, which include workshops and participant research, represent the means by 

which informed choice is ensured. In addition, a formal approval process is sometimes 

used, as a way of ensuring that decisions are justifiable and to benefit the administration 

of the LWIA by assuring that ITA funds are being spent wisely. 

Workshops. Several sites use workshops as an important tool in assisting 

customers in making choices. For example, Baltimore uses a training workshop for all 

customers going on to training. Within that workshop customers learn about their 

training alternatives such as ITA, OJT, or customized training. If they choose the ITA 

method, they attend an ITA workshop, which helps them to prepare their application for 

an ITA that identifies and justifies their selection. Similarly, Southwest Connecticut also 

uses a workshop to prepare customers to conduct active research and teach them how to 

interpret performance information. In a very different approach, SELACO uses a twoweek, peer-managed workshop where customers work together in a team to help each 

other to select appropriate programs of study and vendors. 

Participant Research. A key part of informed choice is to have customers 

research their intended field of study. Most of the demonstration sites implement this by 

specifically requiring or encouraging customers to conduct field research on both training 

occupations and vendors. This typically involves having customers visit vendors to talk 

with staff and observe the facilities. Several also add a requirement that customers must 

either talk with current or former students of the program, interview employers who 

would potentially hire trainees in that occupation, or both. For example, the Pittsburgh 

One-Stop center requires its ITA candidates to interview at least two schools, two 

students who had completed the program, and two potential employers. The case 

manager at another site noted that her LWIA’s research requirement was very effective in 

“bringing back to earth” participants who had come in with poorly thought out ideas. 

Some case managers also felt participant research increased the participant’s commitment 

to the eventual choice, and enhanced the case manager’s knowledge base.

Approval Process. Several sites make a formal approval process a part of an effort 

to promote informed choice, while also serving as a means to assure LWIA management 

that customers are making defensible training decisions. In sites that have such a process, 

potential trainees must submit a formal application or make a presentation before a 

review panel with the authority to approve the ITA. For example, Baltimore’s approval 

process is as follows:
III-16

In Baltimore, prospective trainees must prepare a written justification for their ITA, 

including reasons for wanting the training, evidence that the training is for a 

demand occupation and that the individual has the skills needed to successfully 

complete the training, and a record of research that the participant is required to 

undertake, including from interviews with vendors, former trainees, and employers. 

Prospective trainees then present this justification to a panel of the city’s One-Stop 

center directors who are authorized to approve the ITA. Those whose application is 

deemed incomplete or unsatisfactory must conduct additional research and prepare 

a new application, with the assistance of the case manager, until the review panel is 

convinced that the choice is a wise one. 

Similarly, Golden Crescent has its participants present an oral proposal to an ITA 

committee justifying the career and vendor choices and identifying expected outcomes in 

placement and wages, barriers to completing the training, and a financial plan that 

demonstrates that training and living expenses can be met. 

Local areas in one grantee state, Pennsylvania, are also creating additional 

decision-making tools to assist customer in making better quality decisions. Philadelphia 

is developing a written customer manual for its ITA process that lays out the participant 

rights and responsibilities that underlay an informed choice. The manual will be 

available to other Pennsylvania local areas to customize according to their own 

procedures. Another local area is supporting an Internet start-up company that will 

provide an Internet messaging site on which trainees could post comments on their 

training providers, including prerequisites, curriculum, and instructor quality.

Staff Training and Organization to Support Decision-Making

Because case managers ostensibly assume new responsibilities under the various 

ITA models, one might expect a substantial need for staff training and capacity building. 

In fact, several of the grantees proposed grant activities related to staff training. Overall, 

however, we found that relatively little formal training on ITA systems or the case 

manager’s ITA role had yet occurred. Respondents suggested two reasons for this. First, 

because many of the sites were already using some form of vouchering under JTPA, the 

beginning of the ITA system did not change the case manager’s role much, if at all. No 

site indicated that it had to retrain its front-line staff systematically in order to provide its 

particular type of informed choice. Second, many sites are still gearing up for the ITA 

and have plans for training in the future once their automated systems are in place. For 

example, Georgia and North Carolina expect to provide training on their integrated career 

decision and eligible provider list/consumer report system once the systems are fully up 

and running with performance data. 
III-17

The training that has occurred has been a mix of state-sponsored and local in-house 

training. For example, a number of sites, such as Indianapolis and Metro Portland, 

provided in-house training on their own ITA policies and procedures. Several other sites 

reported that there was some coverage of ITA rules and procedures in their general WIA 

training, either provided in-house, directly by state staff, or by the state training institute. 

Several sites provide training to help case managers play a generic facilitative role, 

because the sites are trying to embed facilitation in the entire range of customer 

relationships. The Baltimore One-Stop center, for example, wants staff to help customers 

to make decisions rather than to tell them about rules and procedures. The center uses 

role-playing to equip staff to handle specialized situations creatively. As part of its grant, 

it was also hiring assessment specialists who would not only work with customers, but 

provide guidance and training to other staff at the center. Similarly, the Three Rivers 

Local Board paid for facilitator training at a local university for any interested case 

managers. 

Apart from capacity building, another key staffing issue as sites move to implement 

ITAs is how they organize staff to assist customers. We found two general approaches. 

Some centers use a single point of contact, while others rely on specialization. In the 

former approach, a single case manager stays with the customer throughout training, 

intensive, and staff-assisted core services. The advantage of this approach is that the case 

manager builds up knowledge of the customer and a personal relationship. Capital Area 

(Raleigh) and Golden Crescent are examples of One-Stop centers where the case 

managers build a personal rapport to aid in the decision-making, even though these two 

sites differ considerably in the way in which case managers provide information and the 

degree of influence over customer choice. Some sites that use a single case manager 

have specialized assessment units or contracts with outside firms for assessments. In the 

second approach, One-Stop centers use specialists on staff in working with customers. 

This approach enables case managers to develop greater expertise in the subjects to 

which they are dedicated. Baltimore has the clearest division of labor, with case 

managers who specialize in job search during core and intensive services, and others who 

focus on assessment and career planning. These staffing patterns and relationships cut 

across both the informed and directed choice models. 

LIMITS ON CUSTOMER CHOICE THROUGH LOCAL POLICIES

Regardless of the customer-choice models that local sites selected, nearly all 

exercised their authority to set limits, predominantly to ensure that funds would be 
III-18

available to support as many trainees as possible. The most common are limits on the 

ITA dollar amount, duration, and permitted uses of the funds. All sites also implicitly 

narrow choice by identifying occupations in demand in the local economy, for which 

training will be supported. Other types of limitations such as residency preferences or 

formal linkages to local economic development are uncommon. Some of these limits are 

summarized in Exhibit III-2.

Dollar and Time Limits. Nearly all of the sites set a dollar limit, or cap, on the 

total amount of money that a participant could receive for an ITA. Of the 18 local areas 

we visited, 16 use caps. The average cap among those 16 areas is about $5,000, ranging 

from a low of $1,700 to a high of $10,000. Three sites provide authority for staff to 

authorize ITAs that are higher than the local cap, if special circumstances warrant. In 

setting their caps, two sites use their community college as a reference. For example, in 

Macomb-St. Clair the Local Board pegged the cap at the cost that the local community 

college charges. In North Carolina, the state requires that any cap be set above the cost 

of training at the community college in order to encourage competition in that state for a 

training market that is already dominated by community colleges.

Nearly all the local sites, including those with no cap, set a two-year duration on the ITA. 

Among the exceptions, one site limits its ITAs to one year, while another sets a monetary 

cap for one year but allows trainees to request a second year of training with the same 

dollar amount. Three sites have no limitation on duration, although one of those 

indicated that, in practice, most of their ITAs are for one year and there is a virtual twoyear limit.
III-19

Exhibit III-2

Local Limits on Amount or Duration of ITA

Local Area (Grantee) Dollar Cap Duration Limit

Baltimore OED $7,000 1 year

Indianapolis PIC $2,500 2 years

Tecumseh Area Partnership 

(Indianapolis PIC)

None 2 years

Macomb/St. Clair Workforce 

Development Board

$5,000 None

Metro Portland worksystems None None

Southeast Los Angeles 

County 

$5,500 (staff can justify 

amounts above the cap)

None (however, ITAs are 

rarely for more than 1 year)

Southwest Connecticut $3,000 1 year

Areas covered by the Metro 

Atlanta Regional Comm. 

(Georgia Dept of Labor)

$8,000 2 years

West Central/Sedalia (MO 

Workforce Development)

$1,700 2 years

Greater Lincoln (Nebraska 

Dept of Labor

$5,000 2 years

Greater Lincoln (Nebraska 

Dept of Labor

$4,000 2 years

Capital Area/Raleigh (North 

Carolina Workforce Development)

$5,600 (State policy that ITA 

must exceed cost of training 

at community college)

2 years

Cincinnati (Ohio Bureau of 

Employment Services)

$5,000 None

Three Rivers Workforce 

Board (Pennsylvania Dept of 

Labor and Industry) 

$10,000 (considering a policy 

to vary cap to promote high 

wage/high growth occ.)

2 years

Golden Crescent (Texas 

Workforce Commission)

None 2 years

Heart of Texas (Texas 

Workforce Commission)

$5,000 2 years

________________

Note: The first column lists the local area we visited (with the name of the ITA/ETP grantee in 

parentheses, if different from the local area).
III-20

Permitted Uses for the ITA. Nearly all the sites permitted ITAs to be used for 

tuition, fees, books, uniforms, and equipment. Only one site limited the ITA to the 

tuition, while one other prohibited its use for fees. Only one site included supportive 

services within the ITA. One of the sites that kept its supportive services separate still 

linked the amount of those services to the size of the ITA. In that site, supportive 

services could not exceed 20 percent of the ITA amount. Yet another site tracked 

supportive services along with the ITA, although the funds came from separate accounts.

Demand Occupations. While the law requires that all training occur in demand 

occupations, sites defined this requirement in different ways. Some relied on a list of 

demand occupations developed by the state; others used locally developed lists. A few 

had no formal lists at all, but instead relied on the case managers’ own knowledge of the 

local economy. Sites with formal state or local lists also varied in whether exceptions 

could be made to fund training not on the list. Most would allow such exceptions if the 

customer could demonstrate that a job would be available once training was complete; a 

few allowed no waivers whatsoever. 

Several sites added additional restrictions to enhance the economic development 

potential of their ITA system. For example, one site is planning to link ITA amounts to

important growth sectors in the local economy, as follows:

The Three Rivers Local Board may consider a new policy in which the 

amount of the ITA would vary with the occupation chosen. Under the policy, 

the Local Board would reserve ITAs with the highest permissible funding 

amounts for training in jobs that are considered critical for regional economic 

growth. The absolute maximum would apply for the occupations that the 

Local Board believes are most important for the local economy and that pay 

the highest wage. Other occupations would be capped at a stipulated 

percentage of the maximum amount, varying with the relative importance of 

the occupation to economic growth in Pittsburgh and surrounding Allegheny 

County and its ability to lead a customer towards a living wage, which is 

expected to be in the $8-$10 range.

Residency Preferences. There are also a few residency preferences to access 

ITAs. Even though WIA removed JTPA’s residency requirement for service to 

economically disadvantaged adults, several sites within the demonstration have decided 

to impose residency preferences on the issuance of ITAs. For example, the Atlanta 

Regional local areas give preferences to residents of their respective LWIAs or to 

dislocated workers formerly employed in those LWIAs, on the grounds that serving those 

outside the area comes with no additional funding. 
III-21

SERVICES PROVIDED TO TRAINEES DURING AND AFTER TRAINING

Services during Training

The extensive investment in the ITA by both the participant (time and effort and 

opportunity costs) and the LWIA (staff time and training outlays) raises the importance 

of ensuring that the customers are successful in their training. One element of this is 

maintaining good connections between the One-Stop center and customers who are in 

training. For the customer, a variety of counseling services may be beneficial or 

necessary to assure training completion. The One-Stop center staff, in turn, will want 

assurance that the participant is attending classes and otherwise making progress in the 

training. Maintaining these connections typically involves the participant, the One-Stop 

center case manager, and the vendor and its staff. All the sites carried out these functions 

in some way, but they differed considerably in the types of services offered or required 

and in who carried out these various responsibilities and services. 

All but one of the sites want trainees to keep in periodic contact with their case 

managers during their training period to verify attendance or to meet with the case 

manager. The most common period used is a monthly meeting or report. However, sites 

differ in whether the responsibility for contact lies with the trainee or the case manager. 

In some sites, the trainees need to check in to file an attendance or a broader progress 

report and could then elect to see a case manager to discuss any concerns that they have 

with their training. Trainees are also supposed to report any problems that might 

interfere with the completion of their training program, such as health or family 

emergencies. The Greater Omaha site wants contact on a more frequent basis. Trainees 

there have to bring in attendance reports signed by the training instructor at least every 

two weeks. This visit coincides with the time customers pick up bus passes, an important 

supportive service for many of them. When the customers come in, the case manager 

gets a chance to talk with them informally. 

Case managers have parallel responsibilities to monitor a trainee’s progress. All 

sites have their case managers monitor progress in the training in some form. In those 

sites that require a personal visit, case managers meet with their customers to solve 

personal problems that might interfere with completion of the program or to review 

supportive services needs. In some sites, such as Southwest Connecticut, where the 

trainee is not required to come in, the case manager checks monthly with a trainee to 

learn about attendance and any concerns with the training. The case managers may even 

make a home visit, if there was a concern about attendance. Another site sends trainees 

periodic surveys mailed to their home; this approach was developed partly because case 
III-22

managers have very heavy caseloads, which make routine personal contacts infeasible. 

Demonstrating another approach, the Georgia ITA coordinator is planning to create an 

Internet-based network to provide study skills to trainees. This system, which will be 

part of the integrated career exploration and consumer report systems, will be available to 

all trainees in the state.

Vendors also provide important services during training. Nearly all have financial 

aid case managers to assist with applications for Pell grants and other forms of financial 

support and a counseling staff to provide training in study skills or help their students 

with general problems. Most of our sites required their vendors to report progress or to 

identify when students have particular problems. Five sites specifically require the 

vendors to provide periodic progress reports, most often monthly. 

Many of the front-line staff we spoke with noted that active counseling is much 

more prevalent among the proprietary schools than public institutions, which are 

predominantly community colleges. The community colleges usually have similar 

counseling available, but usually the student must take the initiative to use such services. 

The proprietary schools, on the other hand, are very active in bringing those services to 

their students. The proprietary schools are also generally better at monitoring student 

progress and reporting to the One-Stop centers than the colleges. Baltimore staff, for 

example, noted that their proprietary schools provide greater levels of support because 

they are much more concerned with demonstrating the institution’s high performance. A 

case manager in Jonesboro (who herself is an employee of a college that operates the 

One-Stop center and is a training vendor) spoke about how much better the proprietary 

schools are at reporting to the case manager information about students who are 

experiencing difficulties. 

However, despite these general patterns, in some places the One-Stop staff reported 

that the community college also does a good job of communicating progress and 

supporting student progress. For example, in Greater Omaha and Greater Lincoln, both 

of which have few private training schools, the community colleges provide good 

counseling services and a host of other supportive services, such as on-site child care and 

support groups for people entering non-traditional employment.

Placement Services

WIA’s performance management requirements make good placement services 

extremely important for all One-Stop customers, including ITA holders. The sites are 
III-23

fairly evenly divided in making the One-Stop center, the vendor, and the customer 

responsible for placement. Some of the One-Stop centers we visited want the customer 

whose training is ending to come in for job search workshops, counseling sessions, 

meetings with job developers, and help in preparing a resume, and to use other core and 

intensive services. For example, Metro Portland has the case manager refer the job 

seeker to an in-house job developer. Capital Area (Raleigh), which makes its case 

managers responsible for outcomes, asks its trainees to come to the One-Stop center two 

weeks before completion of their training to start using job search resources. One-Stop 

staff there note that, in the current tight labor market, it is very easy to place workers who 

have the up-to-date skills provided by their training.

More of the sites, however, rely on placement by vendors. In Greater Lincoln, 

Greater Omaha, Pittsburgh, Allegheny County, and the Atlanta Regional local areas, the 

Local Boards require the vendors to assist program graduates with getting jobs. For 

example, a technical training school in the Pittsburgh area has full-time job developers 

who get bonuses for exceeding placement targets. The vendors in the Atlanta Regional 

local areas predominantly have formal placement programs, some of which we describe 

below:

The vendors in the Atlanta area use a variety of means to provide placement 

assistance. One vendor forms job clubs and has job developers on staff. One 

computer training school that serves predominantly low-income, minority 

students integrates job search into its curriculum and makes all staff 

responsible for placement outcomes. On the other hand, another computer 

training school that serves predominantly upper income dislocated workers 

among its WIA customers facilitates self-directed job search using an 

informal network of the school’s graduates. As an adjunct to this vendor 

activity, one Atlanta Regional local area case manager bring his customers to 

the One-Stop center 60 days before completion to begin job search. 

As with counseling services, proprietary schools generally seem more proactive in 

helping trainees with job placement than public colleges are.

Several sites give the customer the choice of whether to rely on vendor or One-Stop 

placement services, taking advantage of the customer’s obvious interest in prompt and 

remunerative employment. SELACO notes that most of its trainees take advantage of 

vendor services. Nevertheless, case managers encourage their customers to come in if 

they think that they need extra help. Regardless of who is primarily responsible, all the 

One-Stop centers indicate that their full job search facilities, from core and intensive 

services, are available to those who complete training. 
III-24

COORDINATING THE ITA WITH OTHER SERVICES

Seamless service to customers is an expected feature of the integrated system 

intended by WIA, as is the leveraging of funds from multiple sources. Thus, in order to 

understand the full array of resources and services that trainees are accessing, we must 

understand how WIA funds are used in conjunction with funds from other sources. In 

fact, in most of the demonstration sites, the ITA itself is only one part of a complex 

mosaic of funding sources that contributes to training of ITA holders. These sources 

include Pell grants from the U.S. Department of Education, trade-related dislocation 

programs through the unemployment insurance system, vocational rehabilitation state 

training or higher education grants, and welfare sources, to name the most common.

With respect to service integration, we found that co-enrollment and other forms of 

collaboration were highly developed in some sites but weak in others. At the one 

extreme, the two sites in Indiana were notable for an especially high degree of 

collaboration across the various One-Stop partners. Thus, Indianapolis had about onethird of its ITA participants co-enrolled in welfare-to-work, vocational rehabilitation, or 

Trade Adjustment Assistance. Similarly, Tecumseh Area Partnership, also in Indiana, 

had quite a few ITA holders enrolled in vocational rehabilitation. At the other extreme, 

many sites had little or no co-enrollment or active collaboration. The predominant 

explanation for lack of collaboration was that their One-Stop systems were still being 

built, and they expected greater collaboration in the future. 

Of the One-Stop programs, the trade-related dislocations programs, including the 

Trade Adjustment Assistance and the North American Free Trade AgreementTransitional Adjustment Assistance programs, are perhaps the most successful in 

obtaining coordinated enrollments. Both of these programs can pay for training expenses 

and income support while a customer is in training. The latter feature makes these 

programs highly desirable for dislocated workers who are interested in training. Very 

often, because the ITA could be committed before the trade amount was approved, the 

ITA was usually the initial payer and the LWIA received reimbursement once the trade 

amount was approved. Case managers at Allegheny County pointed out that the 

incentive to train was so strong and knowledge of the program was so widespread in the 

community that nearly all eligible dislocated workers come in specifically for training 

services. In this county, co-enrollment is mandatory, and the ITA amounts are 

coordinated with services provided through trade programs and other available funding 

sources. Thus, DOL’s efforts to coordinate the major trade programs with the general 

training programs, which it has been promoting over the last several years, appear to be 
III-25

having some success. There were exceptions, however, including in the several sites, 

such as the Atlanta area, that indicated that co-enrollment was not occurring because they 

were experiencing little trade impact.

Coordination with the Pell grant is more common still, which occurred at virtually 

all sites.6 In managing this coordination, these sites generally adhered to WIA’s 

requirement that Pell funds, among others, should be spent first. However, because the 

ITA amount could be determined and committed immediately, in general ITA funds are 

typically used to begin a training program and then Pell grants are used to provide 

reimbursement from the training vendor once the Pell grant was awarded. Sites either 

considered an estimated Pell award in preparing the ITA, as in Indianapolis and Capital 

Area (Raleigh), or the eventual grant effectively reduced the amount of the ITA, as in 

Cincinnati, Baltimore, and West Central (Sedalia). Several other sites paid for tuition 

through the ITA but used the subsequent Pell grant to defray the cost of supportive 

services.

Personal financial contributions were also a common form of additional support. 

Many of the sites indicated that they expected a personal financial contribution from the 

trainee wherever the ITA amount or other financial resources did not cover the cost of 

training. These amounts are figured into a financial plan that the sites required 

participants to prepare as part of the individual employment plan. Southwest Connecticut 

is perhaps the most vigorous site in obtaining contributions as a matter of policy. The 

Local Board believes that a personal financial contribution will increase a participant’s 

personal stake in the training and the outcomes. Although not widely used, that LWIA 

also offered low-cost loans sponsored by private companies and corporate-funded 

scholarships to ensure that there would be additional resources.

State programs were another important source of funds. For example, in the 

Atlanta Regional local areas, the presence of a state scholarship program funded through 

lottery revenue is central to their ITA strategies. These scholarships have no income 

restrictions and are thus available to virtually all residents. They must be considered the 

first source of payment for training, so residents must apply for these scholarships as well 

 

6 The Pell legislation contains a provision requiring that other federal financial aid programs not 

consider an individual’s eligibility for Pell when computing available resources for that person. At the time 

of the site visits, DOL and the Education Department have issued regulatory guidance that coordination 

between the two funding sources should occur. 
III-26

as for Pell grants. The combination of these funding sources makes the ITA a relatively 

small player in the training marketplace. Pennsylvania also has a state higher education 

assistance program that could offset the ITA. 

SUMMARY

One of the key reform principles that DOL has developed for the implementation of 

WIA is increased customer choice. This is clearly evidenced in the ITA/ETP system, 

which provides for qualifying good training vendors and explicitly guarantees the right of 

customers to choose from among those who qualify. Yet, the system also sets that choice 

within a regulatory framework to assure that Congressional policy is carried out and 

ensure that, when funds are limited, resources are available to serve those whose needs—

low income workers and welfare recipients—have long been recognized. This regulatory 

framework effectively constrains choice to some degree. 

We observed that the policies, practices, and procedures that local areas used in 

implementing the system were quite effective in creating a balance between these two 

tendencies. We observed that each tendency is moderated by a major factor that brings it 

closer to its counterpart. First, customer choice in the ITA system is not the unrestricted 

choice of the commercial marketplace. Rather choice under the ITA system is informed 

by high quality information and reasonable guidance by professional staff. We observed 

in all sites that customers were making choices based on the use of labor market 

information and career guidance systems, staff guidance, and other resources, including 

their own field research. Second, the regulatory framework, which some respondents 

noted is as constraining as that under JTPA, is tempered in all sites by considerable 

flexibility. Our findings on the path that customers follow through pre-ITA services, the 

selection of training occupations and vendors, and the services during and after training 

clearly show a high degree of flexibility across all sites.

Another major factor that enabled the demonstration sites to create a more 

harmonious ITA system was their experience at it. Many of the sites indicated that they 

did not have to change many of their practices, policies, and procedures from those they 

used under JTPA. A few sites said that their ITA systems were virtually no different 

from how they approached training under JTPA. Others indicated that establishing an 

ITA was an additive process: they were able to add certain elements to existing practices 

or policies that were consistent with the ITA system. 
IV-1

IV. DEVELOPING THE ELIGIBLE TRAINING PROVIDER LIST 

AND CONSUMER REPORT SYSTEM

Two key elements of the training system envisioned by WIA are, first, that 

customers should be empowered to make decisions regarding the training program and 

vendor that suit them best, and, second, that, for this to be meaningful choice, it should be 

supported by ample and relevant information made available by the One-Stop system. As 

we have discussed in the previous chapter, centers were actively working to provide 

information to customers to promote their informed choice, by making labor market data 

available, providing assessment and counseling, conducting workshops, and having ITA 

holders conduct field research with former trainees, employers, and vendors. Also 

critical, according to the WIA legislation (e.g., Section 134d4F), is that customer choice 

will be supported through an Eligible Training Provider (ETP) list and Consumer Report 

System (CRS) that will: a) identify those programs and vendors that have been found by 

the state and local workforce board to meet acceptable standards of quality, b) provide 

information in a readily accessible format about each program’s costs, c) provide 

information on vendors’ performance that will permit comparisons across programs with 

respect to program completion and job placement rates of recent trainees (both WIAfunded trainees and others) and their wages, among other things, and d) provide other 

information that may be relevant in helping customers make wise choices. 

According to the vision embedded in the legislation, the ETP and CRS are the 

linchpin of the ITA system, serving as key resources to promote the full information that 

is necessary to support customer choice. Providing these tools helps assure local areas 

and states that they provide choice to customers while still meeting their accountability 

requirements. However, their development has proven to be costly and time-consuming 

undertakings, as we shall see below. In fact, most of our case-study sites are still 

developing the details of these systems. For instance, with respect to the ETP, most have 

yet to make decisions regarding performance benchmarks for subsequent eligibility or 

work out the details of how vendors’ performance will be measured. The development of 

the CRS has proven to be even more difficult; only a few sites had an operational CRS, 

populated with reasonably complete data, at the time of our site visit, and many sites 

expect that it will be quite a while before they do so. Thus, the Final Report of the 

evaluation, due in early 2002, will be able to provide much more information than we 

have available now about what these systems look like, how they were constructed, and 
IV-2

how they work in practice and are used by customers. In this chapter, we provide an 

introduction to these issues by discussing some of the considerations that sites are using 

in building their ETP list and CRS, how they established initial eligibility, and their 

preliminary plans for subsequent eligibility and performance measurement.

DESIGN OF INFORMATION SYSTEMS

At the time of our site visits, all states had developed an ETP list that had been 

distributed to One-Stop centers for their use. These lists took different forms, reflecting 

states’ unique visions for their systems, and they were disseminated in different ways. 

Vision of the Eligible Training Provider List

A primary question that states had grappled with was determining what purposes 

and audiences the ETP list should serve. According to the WIA legislation, the ETP list 

is to serve primarily two functions. First, as the name implies, it constitutes a list of those 

providers whose programs may be considered by adults and dislocated workers who are 

undertaking training funded by WIA (WIA Section 134d4C). Second, the list is to serve 

as a resource for the universal customer who, through core services, is interested in 

conducting research on training providers in the state (WIA Section 134d2F). 

There is potentially some tension between these two objectives. To meet the first 

objective as efficiently as possible the list could be restricted to only those providers 

eligible to redeem an ITA. In this way, ITA holders can examine the universe of 

providers from whom they can undertake training with the least confusion. By contrast,

the universal customer might be interested in researching a more comprehensive list of 

vendors, including those that may not be ITA eligible. How programs managed these 

varying goals differed among the sites we visited. 

Just less than half of the demonstration states gave primacy to the first of these 

objectives, by developing an ETP list intended primarily to meet the needs of WIA 

training customers. In these states, the ETP list consists exclusively of WIA-eligible 

training programs and providers. The logic that these states followed was that similarly 

structured lists containing information on other programs and providers already existed to 

meet the needs of customers in core services. For example, for the sake of expediency 

Pennsylvania was focusing on creating a narrow ETP list that would include information 

only for ITA-approved programs, on the grounds that doing otherwise would be 

duplicative with a more inclusive list already available from the state Department of 

Education. Sometime in the future, this state reasoned, these two lists could be merged to 
IV-3

create a comprehensive list that identified which vendors were WIA approved, but in the 

short-term it felt that its efforts would best be focused on the more limited objectives at 

hand. Another reason for developing a restricted list was to provide a strong incentive for 

vendors to apply for eligibility. According to this logic, vendors would want to apply for 

eligibility for their programs to take advantage of the marketing opportunities that the 

ETP list offered.

By contrast, the remaining states we visited developed a broader ETP list that was 

intended to be a multi-purpose resource. In these states, the ETP list was opened up to 

include non-WIA eligible providers for several reasons. First, they wanted to ease the 

workload for their cross-trained staff, by creating more efficient search tools that are easy 

to use. Rather than different agencies having a unique list for its own purposes or having 

case managers search multiple lists with different levels of certification or types of 

approval, a single list (with indicators denoting which vendors had been approved for 

different purposes) would enable staff members to access all the training options for their 

clients quickly and with ease. For example, in Ohio Works centers, case managers are 

cross-trained and serve multiple programs for which they are responsible for training 

referrals. The database they have developed provides a comprehensive listing of training 

programs in the state while indicating whether or not the program is ITA approved and, 

in some cases, whether it is certified or approved for other funding sources. With a 

comprehensive training provider list, case managers are thus able to access one site for 

information about training vendors, and customers are able to access this information to 

make informed training decisions in a timely fashion.

A second consideration for those developing an inclusive list was to maximize the 

use of the WIA administrative funds that were expended in building the list to begin with. 

Faced with limited funding for the development of their One-Stop infrastructure, and the 

high costs of developing the computer interface for the ETP and CRS, states want to 

leverage their investment in compiling data and developing software by having the 

resultant tools serve multiple purposes. This consideration becomes especially important 

in states that are anticipating a relatively low flow of WIA participants into training, 

because in this circumstance a relatively small number of persons would benefit if the 

ETP list were narrowly restricted. By contrast, including a larger number of providers 

and programs in the CRS justifies the expense of creating this new tool. 

Related to this, states developing an inclusive list wanted a tool that would bridge 

the gap between ITA-funded training and training that might be funded from other 
IV-4

sources. Emphasizing the principles of universal access and customer choice, these states 

chose to make the ETP list a more comprehensive training source for all customers in 

including non-WIA eligible training programs. This inclusive list serves as an important 

resource for all individuals looking for training. Moreover, such a list could serve as a 

resource for employers as well. In Georgia, for example, state representatives sent out 

notices to small and mid-sized employers encouraging them to use the list for their 

incumbent-worker training. These customers would not necessarily have had a use for 

the CRS if non-WIA eligible training programs were not included on the list. 

Finally, another advantage of a broader list is to provide an incentive for vendors to 

seek ITA approval. This explanation was paradoxical given that states adopting a 

restrictive ETP list also provided this as a rationale for their strategy. Both groups 

recognized how difficult it might be to encourage vendors to go through the trouble of 

filling out the required paperwork and collecting the necessary performance data to seek 

eligibility for a program, given that they could generally expect only a small customer 

flow of ITA holders. Thus, states wanted to emphasize the advertising advantages that 

the vendors’ inclusion on the list would offer. Some states felt that restricting the list 

only to ITA eligible providers would best serve this purpose. By contrast, others took the 

opposite approach. For example, the vision expressed to us by respondents in Michigan 

was that any vendor could be included on the list, whether or not it was ITA approved, 

but each must submit essentially the same paperwork and information about its programs, 

including some performance data. Given this, the marginal burden of applying for ITA 

eligibility was expected to be very modest, which, it was hoped, would induce vendors to 

apply. 

These strategies articulated by both groups of states represented their vision of how 

the ETP list could best strike a balance in meeting the needs of ITA holders, other 

potential trainees, case managers, and other stakeholders. However, pragmatic 

considerations were important as well. Thus, in some cases, the strategy followed by 

states for the ETP list was affected by their overall progress towards full implementation 

of WIA. The July 2000 WIA compliance date factored greatly in the planning of all

states. For example, one state modified an existing list of TANF vendors to serve as the 

ETP list. Not only did modifying an existing product seem like the best way to make use 

of existing resources, it was also very expedient because state representatives were 

operating so close to the WIA implementation deadline of July 2000. Other states based 

their ETP list on rosters of vendors that had been approved by state certification bodies. 
IV-5

For example, in Maryland by state law any entity in the state that offers training services 

that is open to the general public must be certified by the Maryland Higher Education 

Commission (MHEC). The state felt that this list served as a very natural starting point 

on which to base the ETP list.

Disseminating Information about Vendors

The Workforce Investment Act (Section 122e4A) stipulates that the ETP list must 

be distributed to the One Stop delivery systems within the State and “be made widely 

available to participants in employment and training activities.” Moreover, the ETP list 

should be bundled with other sources of information in a consumer reports system that 

would, according to the WIA regulations, help adults or dislocated workers to “fully 

understand the options available to him or her in choosing a program of training services” 

(20 CFR 663.570).

As a subsequent section of this chapter will discuss, performance information on 

vendors was almost completely absent at the time of our site visits. Thus, the information 

that states could provide for the ETP list consisted for the most part of basic information 

about vendors (e.g., name, address, etc.) and their programs (course name, duration, 

costs). With wide distribution as their main goal, states made this information available 

either electronically, in paper form, or through a combination of both methods. On the 

one hand, a few states have elaborate systems that enable users to search electronically by 

geography and key word, “shopping cart” features so that users can easily compare across 

vendors, links to each vendor’s Web home page, and other features. A few states (e.g., 

Missouri, North Carolina, and Pennsylvania) have also developed (or are planning to 

develop) customer feedback systems that enable those who have undertaken training to 

post comments on the program’s quality on the Web. At the other extreme, some states 

thus far (or at least at the time of the site visit) have only hard-copy listings or, at best, 

electronic ETP lists in the form of Microsoft Word files or spreadsheets. Clearly, in 

many states much developmental work on the CRS infrastructure remains to be 

accomplished.

Apart from the sheer amount of work that yet needs to occur, states are grappling 

with issues regarding how the data—or how much of the data—should be displayed. For 

example, respondents in some states voiced concern that users, including customers of 

the One-Stop center and WIA partner programs, might misinterpret performance 

information about vendors or not understand the requirements for eligibility. One state 

was contemplating handling this issue by suppressing much performance information, 
IV-6

and thus might simply indicate (in an ETP list that included non-ITA eligible providers) 

whether the program was WIA approved. 

Another consideration concerned how or whether to link information about vendors 

with other data sources in a comprehensive management information system. A few 

states, generally those that have created ETP lists that address the needs of many different 

audiences, have been inclined to link these different data systems. In use by customers, 

case managers, local boards and multiple partner programs, they reach a large, diverse 

audience. Features of these systems vary but can include customer tracking, performance 

information, and reporting capabilities. For example, Georgia has decided to put its ETP 

list and CRS on the state-run Career Information System used by multiple program 

partners in its One-Stop centers. For this state, the existing statewide electronic system 

serves as the best distribution mechanism available and ensures that a large audience will 

be reached. Placing the list on this existing system also allows the state to take full 

advantage of previous state efforts as well as funding earmarked towards electronically 

linking the state. 

Other states also have future plans to link the ETP list to the larger MIS. However, 

our respondents pointed out to us that these efforts will require much time and additional 

resources beyond the scope of this grant in order to be realized. It will be interesting to 

see in the next round of visits to these demonstration sites how much progress has been 

realized and how much, if any, additional funding was invested in the effort.

Still other states embed their vendor list on a larger career-oriented web site, with 

diverse resources and tools to assist customers in making training decisions. These other 

resources might include information about transportation and childcare services, sources 

of financial aid, career planning tools, assessment instruments, and labor market 

information, among other things. An example of one such system, Maryland’s 

CareerNet, is described below: 

Maryland’s CareerNet directs customers with the click of a mouse from 

information about vendors to a variety of other tools and resources that might be 

useful to those making training decisions. For example, customers can take various 

on-line personality tests, a work-interest quiz, and a career inventory. Another link 

directs one to labor market information and information about applying for 

financial aid. Still another provides tools for the job search, including how to 

prepare a resume and develop a job search strategy.

By including the list in this broader context, the state and local areas are able to 

emphasize the overall vision of training as a path to self-sufficiency and career growth.
IV-7

In any case, the time and resources needed to create even less ambitious consumer 

report systems are enormous, as the study sites are finding. Many of these demonstration 

states, even those farthest along in the process, had not fully developed these systems and 

were a long way from having the performance information that WIA will eventually 

require for ITA-approved vendors. In fact, faced with projected substantial time lags 

before some state systems are fully developed, some local-area grantees are using local 

resources to develop interim solutions. For example, both Southwest Connecticut and 

Metro Portland realize that it will be a long while before their states’ consumer reports 

systems are fully functioning and for this reason are contemplating developing local-area 

versions for their own use.

INITIAL ELIGIBILITY APPLICATION PROCEDURES AND REQUIREMENTS

Developing the vendor application process was an important first step in building 

the ETP list. The two key components of this process were marketing to eliciting 

applications from vendors and developing the actual application procedures.

Marketing Efforts by States and Local Areas 

States and local sites varied in their approach to bringing vendors to the eligible 

provider list. The approach they adopted was influenced to some degree by the 

fundamental design decision at the state level of whether the consumer report system was 

intended to include all training resources in the state or was to be limited only to a 

narrower subset. In the former approach, states and local areas needed to solicit all 

possible vendors and then select a subset that met qualifications of the eligible provider 

list for ITA purposes. These sites felt that the first order of business should be to develop 

an inclusive list of ITA-approved vendors for initial eligibility—a Yellow Pages, as one 

respondent called it—and then worry about developing performance criteria to winnow 

the list for subsequent eligibility. Georgia is a good example of a state trying to expand 

its list, especially in its rural areas, where customers might have few choices without 

special outreach efforts. 

The state is very active in attempting to market the eligible provider list to 

vendors. In addition to getting the WIBs to develop active solicitation 

programs, it is working to identify vendors who might be able to serve rural 

areas, in which customers might otherwise encounter severely constrained 

choices. The state also provides active technical assistance to vendors to 

adjust their programs to help them meet training needs in particular areas.

Other states take a more limited approach. Under this scenario, these sites could 

confine marketing to ensuring that the list is large enough to provide sufficient choice for 
IV-8

their ITA customers. In a minimalist approach, local areas needed to offer just enough 

marketing assistance to bring in their good JTPA vendors. For example, at least one state 

indicated that it wanted to get its consumer report system operating properly with a 

smaller universe of eligible providers before moving to expand the list to encompass all 

training providers. It did not expect to push for this expansion until it addressed 

performance issues under subsequent eligibility in PY 2001.

With respect to marketing and disseminating applications to vendors, both states 

and local areas played important roles, but the relative balance between the two varied 

from state to state. Some states have taken a very proactive role in the application 

process. These states sent applications or information on the ETP application process to 

all state licensed or certified training vendors and encouraged them to apply. These states 

felt that it was important to cast as wide a net as possible and make the application 

process as easy as they could for vendors and local areas. Adopting this strategy also 

helped them alleviate their concern that vendors might otherwise be unaware of the new 

ITA system and accompanying application procedures; by sending an application to all 

training providers on a master list, the state could thus ensure that all vendors would have 

access to the application materials. For example, Maryland identified all vendors in the 

state that were certified by the Maryland Higher Education Commission and who were 

thereby authorized to market training services in the state. Local areas were then 

encouraged to follow up, to encourage those vendors to submit an application for ETP 

eligibility.

By contrast, some states left it almost entirely up to the local areas to notify 

vendors of the procedures for applying for ITA eligibility, or they otherwise encouraged 

local areas to engage in heavy recruitment and outreach. For example, Southwest 

Connecticut, SELACO, and Cincinnati had periodic meetings with vendors in their areas 

to explain the ITA system and the application procedures, to complement informational 

sessions conducted by the states. Cincinnati was notably aggressive in its marketing 

efforts, holding quarterly meetings with vendors that will continue beyond initial 

eligibility. 

Submitting an Application for Eligibility

All of the states in this demonstration followed a fairly standard model based on the 

legislative requirements for the initial eligibility process, which stipulate that vendors 

should submit an application to the local board for the area in which the provider desires 

to provide training services. All states followed this requirement, but some variations did 
IV-9

occur due to basic administrative differences. The typical model used by states aligns 

with the procedures required in the legislation and can be described as follows:

1. The vendor completes an application to the ETP list for each of its 

programs.

2. The application is submitted to the local area board either directly to the 

local board where the vendor is seeking eligibility, or to the state who in 

turn forwards it to the relevant local areas. 

3. The local board reviews the application and forwards it to the state with a 

recommendation for entry on the ETP list. 

4. The state reviews the application and either denies or accepts the 

application for eligibility.

5. The provider and local board receive notification of acceptance or denial. 

6. Providers who are denied entry to the list may choose to appeal to the 

state or local board following set appeal procedures. 

The one variant, implicit in the description of step 2 provided above, is that in most 

states vendors would submit applications directly to the local area or areas to which they 

were applying, while, in other states applications would be sent to the state who would in 

turn forward them to the relevant local area or areas. The advantages of the latter 

approach, it was felt, were that vendors need not submit multiple applications for the 

same program to different local areas, potentially needing to meet various and 

idiosyncratic local area guidelines, but could instead submit a single application only. 

This more streamlined process was viewed as removing a potential major impediment to 

vendors’ wanting to apply, as well as substantially easing the burden on the local areas. 

In either case, the local board remained the first arbiter of whether the vendor’s 

application was approved. Thus, even in the states that were recipients of applications 

first, the local board still made the initial decision about whether the vendor’s application 

should be recommended for inclusion on the state list. For example, in Michigan, the 

state receives the application and then forwards it to the appropriate local boards for 

approval. The local boards in this example still retain the authority to give, or withhold, 

their approval.

Also as a way of streamlining the application process, over half of the states we 

visited made it possible for vendors to submit applications electronically. The remaining 

states that do not yet have electronic application procedures are creating the infrastructure 

necessary for them to do so, in some cases using funds from this grant. Although the 

specifics vary, where electronic application is an option vendors are able to download a 
IV-10

copy of the application from the Internet to fill out and mail in to the appropriate local 

board or state agency. Most of these states also allow vendors to email or submit a 

completed application over the Internet directly to a board or state clearinghouse. Several 

of the states are allowing both paper and electronic applications as acceptable forms of 

submission, though at least one of the states will only allow electronically submitted 

applications once its electronic system is fully functioning. 

States that accepted electronic applications felt that doing so expedited the process 

in a major way. For example, the burden of having to keypunch data entries could be 

entirely eliminated. Additionally, a preset electronic application ensures that all 

necessary information will be collected from the vendor, obviating the need for callbacks or otherwise dealing with incomplete applications. For example, in Texas, the 

electronic system will not allow an application to be submitted if certain data fields are 

incomplete or missing. With an electronic process in place, approval of applications also 

proved to be a much easier task, in that a computer program can be created to check 

automatically that vendors are meeting minimum requirements for approval to the ETP 

list (such as performance benchmarks). This benefit will be most noticed in subsequent 

eligibility as vendors and states are faced with processing the large amount of anticipated 

performance data. These new electronic systems should make the application process 

and the submittal of performance data easier for vendors, local boards, and the state alike. 

Information Required for Application

All of the states require the same basic vendor and program information on the 

application form. This basic information includes vendor/institution name, contact 

person, address, information on accreditation, and training provided. Typical program 

data include name of program, course content, certificate/degree awarded, mode of 

delivery, hours of instruction, credits, costs, and program goals. As we will discuss 

shortly, most states waived any requirements for performance information for initial 

eligibility, even for non-exempt vendors, though it could be provided if the vendor had it 

available. For example, in California, the state invited vendors to submit recent 

performance data but flagged this information as “self-reported by the providers and has 

not been verified.” This performance information does not effect a vendor’s inclusion on 

the ETP list.

Several of the demonstration states also explicitly required that providers have 

obtained state certification and licenses to provide training before they apply for 

eligibility to the ETP list. These certifications and licensures were mandated by state law 
IV-11

well before the enactment of WIA. States gave two reasons for requiring this basic state 

certification or license before an application for ETP eligibility would be approved. First, 

they used the state certification as a way of ensuring that vendors met minimum state 

standards for quality. In addition, reliance on a pre-existing list of state-certified vendors 

was very expedient, in that it provided an obvious starting point for developing the ETP 

list and served as a ready means for identifying vendors from whom applications should 

be sought. 

These certification processes vary in scope and content to some degree. In general, 

however, they focus on process rather than outcomes, considering, for example, whether 

curricula and equipment are up-to-date, whether facilities are adequate, and whether 

student-to-staff ratios are low enough. In Maryland, the state requires the Higher 

Education Commission (MHEC) to approve the provider in a fairly rigorous site visit. 

Every public or proprietary post-secondary school offering training to the general public 

must have certification from MHEC, so it seemed obvious to use this list as the starting 

point for ITA eligibility. Similarly, in Oregon respondents stated that requiring that 

providers be licensed helps create an initial quality assurance before ETP subsequent 

eligibility rules are put in place. 

One complication is that states requiring state certification for providers have in 

some cases had to set up special processes to deal with the large influx of applications 

from vendors applying for inclusion to the ETP list. In Oregon, for example, while 

reviewing applications to the ETP list, state representatives discovered that some 

providers were offering training courses without proper certification. To ensure that 

applications from new providers and those not certified will be sped through the 

certification process, the state has set up a quick certification process so that providers 

can get on the ETP list in a timely way. Though the state does not want to create too 

many bureaucratic processes, they feel that this state certification is necessary and 

ultimately a benefit to all parties. 

An additional difficulty is that, in some cases, requiring state certification is serving 

to exclude from the ETP list vendors that might have been used frequently under JTPA, 

sometimes with good results. For example, in Connecticut, providers without 

certification from the Department of Human Services cannot offer training services to the 

public or advertise. However, under JTPA, non-certified vendors in this state could forge 

agreements with a local job-training agency to conduct class-size training. Given WIA’s 

reduced emphasis on contracted training, providers lacking certification will be little used 
IV-12

and might have difficulty finding enough other business to stay afloat. Now, some of 

these training providers are seeking state certification to stay afloat.

Developing Regional Approval Systems

As we have discussed, Local Boards review vendors’ applications for eligibility 

and decide whether or not they should be approved and forwarded to the state for 

inclusion on the state list. Local areas also are empowered to set more stringent 

performance criteria beyond those established by the state. At the same time, pursuant to 

20 CFR 663.585, some sites hold that ITA holders are free to choose any vendor on the 

state list, so long as the training program is for an occupation in demand. This set of 

circumstances gives rise to the possibility that a customer issued an ITA by one local area 

could use it to procure training services from a vendor that had been denied eligibility by 

that local area but approved by an adjacent one. 

Several of the case-study sites were disturbed by this possibility, and stated that 

they would be very reluctant to expend their training funds for services at a vendor that 

they had denied for eligibility. As a precaution, they were attempting to coordinate the 

vendor approval process across adjacent local areas, at least to some degree. Doing so 

was in fact a chief focus of Macomb-St. Clair’s grant plan. This grantee had used its 

grant funds to hire a consultant who was serving as a regional coordinator responsible for 

identifying existing variation across local areas in the Detroit metropolitan area, not only 

with respect to their vendor approval criteria, but also regarding caps on ITA costs, the 

maximum allowable duration of training, how demand occupations were defined, and so 

on. The consultant is facilitating the coordina tion of policy formulations across the local 

areas to achieve greater consistency. 

The several local areas that make up metropolitan Atlanta developed a different 

approach, specifically focused on the problem of ensuring regional agreement with 

respect to vendor suitability. These areas empowered the Atlanta Regional Commission 

to act on their behalf in reviewing vendor applications and deciding which ones should be 

forwarded to the state for approval. 

A third demonstration site, North Carolina, adopted yet a different approach to the 

same problem. This state was including separate data fields in its consumer report 

system to identify specifically which programs had been approved by which local areas. 

With this information readily at hand, potential trainees and their case managers could at 

least quickly identify vendors that the local area had deemed as unsatisfactory.
IV-13

SUBSEQUENT ELIGIBILITY APPLICATIONS AND PROCEDURES

Only Texas, one of three WIA early implementing states in our sample, had 

actually begun subsequent eligibility at the time of the site visit. All the others did not 

face a deadline for procedures and standards until at least PY 2001. Thus, few of them 

had finalized their subsequent eligibility policies and, in some cases, had given them little 

thought. Other than Texas, only Maryland, Missouri, and Ohio had made considerable 

progress in developing subsequent eligibility requirements. In the remaining states, state 

representatives and ITA work groups were hard at work. Several of the states hoped to 

have recommendations and decisions from these work groups during the first few months 

of 2001. 

One of the reasons for this delay was the difficulty in establishing performance 

guidelines as well as gathering and monitoring performance data. Determining final 

performance measures has been difficult as states attempt to satisfy all entities involved, 

including Local Boards, community colleges, private training vendors, One-Stop center 

operators, case managers, and the customers themselves. As described in the next 

section, states have had to change existing policies and create new definitions before 

determining final procedures. 

Given these difficulties, several of the states admitted to purposefully postponing 

subsequent eligibility for as long as possible. In fact, one state anticipates requesting an 

extension to use initial eligibility guidelines for a full two years. 

Most of the states expect a huge drop-off in the number of providers on their ETP 

list once subsequent eligibility begins. Texas, the only state that has entered subsequent 

eligibility, in fact experienced a substantial drop-off of vendors applying and becoming 

eligible for the ETP list. One respondent estimated that the ETP list had fallen by 85% 

from initial to subsequent eligibility. The overwhelming reason given for this drop-off 

was that vendors, mostly community colleges, were unwilling to undertake the difficulty 

and expenditure of time and resources necessary to gather and submit performance 

information, when they expect that only a trickle of ITA customers will result. 

Another issue that Texas has dealt with concerns the process for approving newer 

programs and those that have not served any WIA participants in a program year. With 

DOL’s approval, the state decided that such programs may be re-certified for one 

additional year (this option does not apply to performance data pertaining to the WIA 

population because the vendor may collect this information from the state directly). If a 

vendor has not trained any WIA participants 90 days prior to the expiration date for 
IV-14

initial eligibility, then a local board may also exercise this option and grant the vendor recertification for one additional year. 

PERFORMANCE MEASURES

Developing performance benchmarks for judging vendors’ success at serving 

trainees, as is envisioned by the ETP application process, has proven to be extraordinarily 

difficult. As a stopgap approach, most sites in our study waived performance 

requirements for initial eligibility and have yet to make much progress in developing 

them for subsequent eligibility. Among the thorny issues with which they are grappling 

are defining key terms and developing necessary and appropriate data collection systems.

Performance Criteria for Initial Eligibility

In keeping with WIA’s requirements, degree-granting post-secondary institutions 

are granted automatic initial eligibility so long as they apply, but other training vendors 

may need to meet minimum performance requirements. In fact, all but two of the states 

we visited as part of this demonstration, Missouri and Texas, waived any performance 

requirements for initial eligibility for all vendors. This decision greatly affects the way 

initial eligibility functions in these states as well as how subsequent eligibility will work 

in the next program year. The overwhelming reason that states gave for waiving 

performance requirements for initial eligibility was that they were not sure what 

requirements they should adopt and needed to confront complicated issues about how key 

measures should be defined and operationalized. Moreover, in most of these states the 

information systems needed to collect, process, and display the volume of information 

that performance requirements would imply were not operational at the time initial 

eligibility began in July 2000. Clearly, states expected that establishing performance 

requirements for eligibility would give rise to extraordinarily complicated measurement 

and data issues, and they wanted to give themselves time to address them in a thoughtful 

and deliberate way.

Another reason for states’ waiving performance measures under initial eligibility 

was to address the concerns of many vendors, especially public institutions, who were 

anxious about what might be required and how the new system would work. As will be 

discussed in the next chapter, community colleges admitted that they were not nearly 

ready to provide performance information about their programs and were very 

uncomfortable with the levels of performance they might show if they did so. For 

example, some community colleges worried that their open-admissions policies would 

make them appear to be very poor performers. In recognition of these very legitimate 
IV-15

concerns, states made the decision to waive performance requirements as a sign to 

vendors that they are important to the system and that the state understands their 

concerns. 

States also felt that waiving performance requirements would help to ease the 

transition to WIA for vendors. Providers, like local areas, case managers and customers, 

need time to get used to the new way of conducting business that an ITA and ETP system 

implies—for example, by taking more care to support students through training and 

afterwards to see that they complete their training and obtain employment. Moreover, on 

a more practical note, waiving performance measures allowed the states to retain the 

large numbers of providers they felt they would lose if performance requirements were 

imposed. During initial eligibility, states hoped, they would be able to work out many of 

the system difficulties and have the opportunity to demonstrate to providers that ETP 

eligibility was valuable and worth their added effort. Interestingly, many of them also are 

requiring vendors as part of the application for initial eligibility to agree to begin 

gathering and submit the required performance data in subsequent years. Thus, they are 

attempting to ease the burden on vendors in the short-run, while endeavoring to get them 

to commit to be players in the system once performance requirements are imposed.

Performance Criteria for Subsequent Eligibility

Approximately two-thirds of the states in our sample were still grappling with these 

issues at the time of our site visit, and thus had not decided on final performance 

measures for subsequent eligibility. Many of them, in fact, were not even close to doing 

so. Conversely, four states finalized their performance measurement policies, or at least 

had developed concrete recommendations that were being fine-tuned or circulated for 

comment. 

Across all states, however, determining the performance criteria for subsequent 

eligibility as well as developing the necessary data systems to support them have been 

time consuming exercises, as states have endeavored to make decisions regarding 

complex issues while balancing the needs of all parties involved. The majority of the 

states convened work groups made up of representatives from local boards, proprietary 

schools, and community colleges and state officials. In one of the states the work group 

met every other week for six consecutive months to determine what performance data 

vendors should report for subsequent eligibility and what minimal levels of performance 

would be required. 
IV-16

A key consideration has been establishing performance criteria that are rigorous 

enough to ensure a minimum level of quality among vendors who are certified as being 

eligible, while not establishing them so high that so many vendors will be excluded from 

the ETP list as to unduly restrict customer choice. Establishing fairly lenient criteria for 

eligibility also brings the associated risk of reduced expectations by conveying the 

message that mediocre performance is satisfactory. Another very practical consideration 

has been knowing at what levels to establish performance requirements in the absence of 

having good historical data about what actual performance has been. For example, states 

that in principle would like to establish performance levels at a certain percentile of 

performance find that they have no way of knowing what absolute score that percentile 

would correspond to. 

The four states that were close to finalizing their performance requirements at the 

time of our site visit show that states balance these objectives and considerations very 

differently, partly as a function of the sophistication of their existing data systems and 

their previous experience with collecting performance information from vendors. For 

example, Maryland has limited historical information about vendor performance and is 

thus leaning towards establishing fairly relaxed performance criteria for subsequent 

eligibility for at least the next year or two, until enough performance data are 

accumulated so that it would be positioned to make a more informed decision. In this 

state, vendors, in collaboration with the state, will be collecting performance information 

on all the WIA-required measures, but, as of now, the only performance benchmarks 

required for subsequent eligibility will pertain to employment rates for WIA-funded and 

all trainees. The exact minimum benchmarks on these two employment measures were 

still being debated. However, the state will endeavor to establish a level that will not 

exclude an excessive number of vendors, while being high enough to represent a sound 

achievement that will keep vendors competitive. In setting the benchmarks, the state will 

also take into consideration performance levels that the state has negotiated with the DOL 

Regional Office on the related WIA core measures, the adult and dislocated worker 

entered employment rates. No other performance requirements will be imposed at this 

time. However, the state envisions using the first several years of subsequent eligibility 

to begin amassing a database of vendor performance on all remaining measures, so that 

benchmarks can be established on them in a reasonable way later. 

At the other extreme, Texas, with a longer history of tracking the performance of 

training providers, has decided on a somewhat more stringent approach for subsequent 
IV-17

eligibility. This state has already decided on its minimum benchmarks for PY 01 as 

follows:

• Performance requirements for all trainees

− Program completion rate: Percentage of all participants 

completing the applicable program conducted by the provider. -- 60%

− Entered employment rate: Percentage of all participants who 

obtained unsubsidized employment. -- 60%

− Average wage at placement: Average wage at placement 

of all individuals who were employed (set at 120% of -- $6.18

federal minimum wage).

• Performance requirements for WIA-funded trainees

− Entered employment rate: Percentage of WIA-supported 

program completers who obtained unsubsidized employment. -- 65%

− Employment retention rate: Percentage of WIA-supported

completers who were employed six months after completion. -- 70%

− Average quarterly wages: Average quarterly wage of WIAsupported completers who were employed six months -- $2,512

after completion.

Defining Key Terms

Before establishing performance criteria, states are finding that one important 

conceptual hurdle is deciding how to define key terms. The most fundamental decision is 

what counts as a “program.” Because the ETP list is in actuality a list of training 

programs, rather than just a list of vendors, defining what constitutes a program is 

essential even before the ETP list can be established, let alone before performance criteria 

are imposed. The regulations (20 CFR 663.508) provide some guidance by defining a 

program as one or more courses that, upon successful completion, lead to a certificate or 

degree, a competency or skill recognized by employers, or additional skills generally 

recognized by employers. Certificate or degree programs can be identified as “programs” 

according to this definition very straightforwardly. However, substantial ambiguity 

arises for individuals who may take variable sequences of courses, as they often do at 

community colleges. Although the specific approaches vary, states generally handle this 

dilemma by allowing vendors to self-define what constitutes a program for which they 

want to seek eligibility. Vendors, in turn, specify the course sequence and completion 

requirements as part of the application packet. Also, the same course sequence provided 

by the vendor at different physical locations will generally count as separate programs.
IV-18

Taking this complication one step further, a state-organized workgroup in Oregon 

found that developing a clear definition of a training program required that they first 

clarify what they considered to be an intensive rather than a training service. This group 

created new service categories within intensive service to represent a number of shortterm training options, including courses in computer literacy, professional development 

skills, and individual employment skills, that involve less than 600 hours of classroom 

time. Because these courses are classified within intensive services, customers can enroll 

in them without having been issued an ITA. Although the state does not require vendors 

to place these courses on the state ETP list, it does recommend that vendors do so for the 

sake of quality assurance. 

States are grappling with a variety of other definitional issues that will also 

determine how vendors’ performance is measured. At the time of our site visit, few 

states had resolved these issues, but most were well aware of their implications. Some of 

these discussions concern how to define an enrollee. Along these lines, one concern that 

vendors have, particularly community colleges, is that some persons might enroll in the 

first course of a sequence that makes up a “program” on the ETP list without necessarily 

intending to complete the entire sequence. Others (e.g., retirees or those pursuing an 

avocation) might complete the program but have no intention of obtaining employment in 

a related field. Under such circumstances, vendors worry that their completion and 

employment rates might look quite dismal if such persons are counted as enrollees, 

without it necessarily reflecting anything meaningful about the vendor’s performance. At 

least a few states have decided to resolve this difficulty by counting individuals as 

enrolled only if at the outset they formally declare their intention to take all courses in the 

sequence and pursue employment at the training’s conclusion. Maryland provides an 

example of this.

Once the program has been defined and the cohort of those enrolled has been 

specified it would seem straightforward to identify completers. When to count a person 

as a non-completer is proving somewhat more controversial, however, because some 

states want to make allowances for the fact that some enrollees may interrupt their 

training for family or medical, while still intending to complete eventually. One state in 

our sample is fairly hard-nosed in its definition and identifies non-completers as those 

who failed to complete during the reporting period if they were expected to do so. 

Another state measures completion at one-and-a-half times the normal expected 
IV-19

completion date, to allow for the possibility that the student experienced a temporary 

interruption of training. 

Data Collection

Because so many of the decisions about how to define performance were still being 

debated in the case-study states at the time of our site visits, little information was 

available about data collection strategies. Nonetheless, we can make some general 

observations based on the progress that states have made or plans they had developed.

Not unexpectedly, we learned that virtually all of the states are developing 

procedures to use UI wage records to collect employment-related performance data, as is 

required by the legislation. Only one state, Nebraska, expressed a serious concern about 

confidentiality issues that might preclude this possibility, but even it was confident that 

they would be resolved satisfactorily. States cite multiple reasons for relying on UI wage 

matching so heavily. These include the imperatives of ensuring that data are collected 

from a reliable source and in a uniform manner across all vendors. Moreover, using this 

source substantially relieves the burden on vendors, which is a key consideration if one is 

concerned about inducing them to apply for eligibility. In short, the state has the 

resources and technology to collect employment information very readily, whereas many 

providers do not.

At the same time, the drawbacks of using UI data were recognized very clearly by 

our state respondents. These include the long time lag between when an individual 

begins employment and when the associa ted employment information is available from 

the appropriate state agency. Incomplete coverage was also mentioned, including the fact 

that some types of employment will not show up in UI files (e.g., self-employment), nor 

will employment in another state (without an inter-state agreement, along the lines of the 

Wage Record Interchange System).1 For these reasons, two states have already decided 

that vendors could supplement UI data on employment with information that the vendors 

gather from their own sources (e.g., surveys), if they choose. Other states are still 

weighing this possibility.

By contrast, data on program completion rates will typically be provided by the 

vendors themselves. In an exception, one state is planning on receiving individual-level 

 

1 The Wage Record Interchange System has been created to allow states to conduct matches with 

other states’ UI files, but participation in this system is voluntary.
IV-20

enrollment data files from the vendors, from which it will compute each program’s 

completion rate. It believes that this strategy not only eases the burden on vendors, but is 

the best way of ensuring data quality and comparability. We emphasize that, with a few 

exceptions, these decisions were tentative, as states are still formalizing their intended 

procedures.

Because of the very vocal concerns of vendors about the problems and hardships of 

collecting performance data, a few states have exercised creativity in an attempt to ease 

the burden of collecting performance information for their providers as best they could. 

For example, Pennsylvania, along with a few other states, has adopted a hardship waiver 

for its providers who can prove that collecting performance data will cause a major 

burden to the training organization. Georgia hoped to use performance information from 

accrediting bodies in the state as an alternate means of collecting performance 

information for the CRS, although state officials are finding that most accrediting bodies 

are not very confident of the reliability of their own data and are in fact looking to the 

state’s CRS to meet their own informational needs. 

Another state, Texas, also exercised resourcefulness to ease the burden of 

collecting performance information for their providers. One strategy that this state 

developed was to enable providers who are approved by the Texas Higher Education 

Coordinating Board to use data on program completion rates required for certification 

from that body in lieu of providing data explicitly to measure completion in accordance 

with the CRS, on the grounds that the former is substantially similar. 

PAYMENT SYSTEMS

Because many of the sites used voucher-like systems in the past, there is relatively 

little change in the payment systems that they used. For example, the Pittsburgh, 

Allegheny County, and the Atlanta Regional local areas used the identical methods of 

contracting and paying vendors that they had used under JTPA. In all those sites, the

financial offices of the LWIAs executed non-financial agreements with vendors on the 

eligible provider list. When a participant receives an ITA, he or she presents the voucher 

to the training vendor, who then submits an invoice to the LWIA’s financial office to be 

paid. 

Carrying over payment methods from JTPA eased the transition to the ITA system, 

but some administrators noted that these “legacy” methods are cumbersome and ill suited 

to the requirements of a market-based system. Some of the sites indicated in their grant 
IV-21

applications that they wanted to modernize their payment and financial tracking. Some 

planned to add financial components to their ITA computer systems to track expenditures 

and provide for payment to vendors. Others wanted to develop systems that would allow 

customers to track their ITA balances electronically. However, for the most part these 

financial systems were still under development at the time of the site visits.

In another innovation, one site, the Three Rivers Local Board, planned to introduce 

a “smart card” payment system, which would not require the LWIA staff to prepare 

warrants and issue paper checks. It planned to use its funds from the demonstration grant 

to work with a local bank to develop such a smart card. Board administrators hoped that 

this would free them from the strictures and costs of the cumbersome public financial 

system. Unfortunately, the board had to drop the idea because it proved too expensive 

for small-scale ITA operations.

However payments are made, they can be tied to performance benchmarks realized 

by the trainee. Only one site, Southwest Connecticut, was exercising this option. In this 

site, the local area would pay 50% of the tuition to its vendors only when the participant 

completed 50% of the program, an additional 25% when the participant completed the 

training, and the final 25% when the participant obtained employment.

SUMMARY

The development of the ETP list and consumer report system is extraordinarily 

complex. Not only do they require an enormous investment on the part of local areas, 

state administrators, and, to some degree vendors, but thorny conceptual issues need to be 

resolved, relating to what the CRS should represent, what benchmarks should be used to 

establish eligibility for vendors, and how performance measures should be defined and 

measured, among other issues. With few exceptions, the states and local areas in our 

sample had made limited progress in resolving these issues. 

Decisions or policies that had been established reflected substantial variability 

across sites, as each endeavored to shape the ETP and consumer report system in a way 

that it felt would best meet the needs of the diverse stakeholders involved, including 

program administrators, trainees, and public and private vendors. For example, some 

states were developing a CRS that included non-ITA approved vendors, in an effort to 

improve the comprehensiveness of the system for customers in core services and leverage 

the resources they were spending on system development; others, by contrast, were 

developing a narrow list that included just eligible training providers under WIA. 
IV-22

Similarly, some were casting a wide net by endeavoring to get as many vendors initially 

approved to accept the ITA as possible, with the thought that they would winnow the list 

in the future once data systems for measuring performance were better established; 

others, by contrast, were more tentative starting out and felt that their interests would be 

better served by starting with a smaller list of vendors whose quality they could attest to, 

with the plan for expanding the list once the basic infrastructure was better established. 

At this stage of system development, states also varied greatly in the complexity of the 

computer interface that they offered customers and the comprehensiveness of the 

information and tools that were available on-line.

Although all states need to make substantial progress to attain their complete vision 

for system development, no doubt the biggest stumbling block that all of them have 

realized thus far has been with respect to how the performance of vendors should be 

measured. Conceptual issues having to do with the definition of key terms—such as who 

counts as an enrollee or completer—are still being resolved in all but a few of the states. 

Operational issues are just as complex, such as establishing the data interchange systems 

for UI matching. 

Clearly, substantial work remains to be accomplished if WIA’s vision for an ITA 

training system with rich information to support customer choice is to be realized.
V-1

V. TRAINING VENDORS: 

INVOLVEMENT AND PERSPECTIVES

This chapter discusses the ITA system from the point of view of the institutions 

that provide training to ITA holders. Training vendors are a diverse group. We use this 

diversity as a departure point to view the network of vendors available to any particular 

local demonstration site and examine how that network serves the needs of the ITA 

customers and system. Our discussion of vendor interactions with customers focuses on 

several key factors affecting customer choice, including the number of vendors and 

programs, vendor accommodations to student needs, and recruiting practices. We 

conclude the chapter with a general assessment of the impact of ITAs on the number and 

types of vendors and on the general structure of the training marketplace.

TYPES AND NUMBERS OF VENDORS

In the local areas we studied a wide variety of vendors are present, running the 

gamut from four-year colleges to proprietary vocational schools to community-based 

organizations. They are quite distinct in the way they relate to the ITA system and the 

training market niches they fill. We looked primarily at public and proprietary schools in 

this first round of site visits, and found important distinctions between them. 

The public institutions, especially community colleges, are ubiquitous and 

represent an important training resource in all the sites. Community colleges are notable 

for their lower tuition costs, breadth of offerings, and access to degree programs. 

However, the colleges tend to adhere to a regular academic calendar, with courses 

beginning at only a few regularly scheduled dates. Moreover, because community 

colleges are typically very large institutions, non-traditional students can easily feel lost 

in this setting. 

By contrast, the proprietary schools whose representatives we met characterized 

themselves as being active in the marketplace and highly responsive to customer needs. 

For example, a vocational school that trains people in a number of manual trades in 

Pittsburgh and Allegheny County offers shorter term evening training in some subjects 

for currently employed workers. This school offers an associates degree in many of its 

programs, and, like other proprietary schools that we studied, has linkages to degreegranting four-year colleges. The school also would establish a class whenever a public 

agency could bring together 15 students. 
V-2

Some proprietary schools, especially those in large metropolitan areas with a large 

variety of schools, specialize in serving particular groups or providing particular learning 

environments. In the Atlanta Regional local areas, for example, where there is a strong 

emphasis on computer training, some schools specialize in serving dislocated workers 

while another serves low-income adults with limited basic skills. The latter school offers 

a “boot camp” approach through which instructors helped students with a range of basic, 

life, and labor market skills in addition to teaching them occupational skills. Other 

schools use different curricula and pedagogical methods designed to appeal to different 

types of students. For example, one computer school uses an intensive approach in the 

classroom and expects students to complete practice exercises on their own in the 

computer labs. Others offer a more structured classroom environment with greater 

reliance on the instructor demonstrating techniques to solve relevant computer and 

network problems.

While we did not visit with any community-based organizations that provide ITA 

training, Local Board and One-Stop staff noted that many of these organizations provided 

training to economically disadvantaged adults under JTPA, but are not likely to be 

successful under an ITA system because of their traditionally narrow customer base. In 

addition, their frequent reliance on contract training puts them at risk of losing more 

customers than they might gain in a competitive marketplace. Further, they are usually 

thinly capitalized and are likely to have difficulty coping with an irregular flow of ITA 

students. 

Not only types but also sheer numbers of vendors are important in an ITA system, 

because a larger number of vendors and programs obviously contributes to enhancing 

customer choice. Because the number of training vendors generally is larger in the 

demonstration sites located in large metropolitan areas, customers in these areas will 

generally have a greater degree of choice. For example, at the time of the site visits 

Baltimore reported 70-80 vendors, each with about 5 or 6 programs. Macomb-St. Clair 

and Indianapolis had 349 and 240 programs respectively. By contrast, Nebraska had only 

100 vendors statewide. Not surprisingly, our urban respondents felt that they had a good 

network from which customers could choose. Yet, even our respondents in rural areas 

and smaller urban areas considered their vendor lists to be sufficient to provide ITA 

customers with good quality training even though there were fewer choices.

Unfortunately, the range of choice may decline when subsequent eligibility begins, 

regardless of the area’s population density. Texas had 8,000 programs statewide for 
V-3

initial eligibility, but that number fell to 1,000 for subsequent eligibility. Moreover, the 

number may fall even further if more of the state’s community colleges decide not to 

participate after the first year of subsequent eligibility, as they have threatened to do 

because of their objections to the performance tracking requirements of the eligible 

provider list. Staff in the Capital Area (Raleigh), which has over 200 vendors with a 

wide range of programs, also expect their vendor list to contract substantially once full 

performance information is required.

Some local areas are trying to counteract these trends by expanding the list of 

vendors through outreach, while others are trying innovative methods to tap new sources. 

The Lancaster County LWIA in Pennsylvania, for example, is using demonstration grant 

funds to increase the scope of its vendor group by linking the ITA to the training 

resources of local employers, as follows:

This LWIA is working to include training provided by the area’s businesses 

for its own employees as part of the ETP system, with the expectation that the 

training would thereby become accessible to ITA holders not employed by 

the firm. Such an arrangement is believed to be beneficial to employers, as it 

enables them to share their training resources, to some degree defray the costs 

of their own in-house training, and participate as part of a larger training 

marketplace. At the same time, it benefits the WIA system by increasing the 

training choices for ITA and other WIA participants. Thus, Lancaster 

expects that this innovation will create a more efficient local market for 

training. However, it is still working on methods to measure performance for 

the employer-based, in-house training.1

VENDORS AND CUSTOMERS

Because they can no longer count on contracts, or even direct referrals, from job 

training, as they may have in the past, vendors must be responsive to customers’ needs 

and, potentially, engage in some direct recruitment of ITA holders if they are to be 

successful training vendors under WIA.

Vendor Responsiveness to Customers

Vendors can be responsive to customers in several ways. Most importantly, they 

can offer successful programs that prepare ITA holders for good quality jobs that are in 

demand and work to ensure that their trainees complete programs and get placed at high 

wages. This is in essence the training marketplace that WIA envisions. However, 

 

1 We have recently learned that this effort may be abandoned, as a new state law is requiring that all 

training vendors must be state certified.
V-4

vendors may also respond to customers’ needs through improvements in accessibility, 

such as reducing costs or adjusting the timing, location, or duration of programs and 

adding auxiliary services.

On the topic of costs, our respondents generally did not suggest that vendors are 

responding to customers through pricing mechanisms, even in those sites where training 

costs regularly exceed ITA caps, and Pell grants and ITA holders must contribute 

personal funds or take out loans to make up the difference. 

The timing of programs plays an important role in responding to customer needs 

and has great immediacy to prospective trainees. Proprietary schools are widely 

considered to be quite responsive in this regard. Some schools, especially those 

providing computer training, offer open entry so that a student can begin the training at 

almost any point. One such school in the Atlanta Regional local areas, for example, 

accepts students at any time, although it suggests to prospective students that the best 

starting times are on Mondays and Wednesdays. Although it is less common, community 

colleges can also be flexible. A community college in the Macomb-St. Clair area, for 

example, increased the frequency with which it offers its courses, from three times-peryear to five times-per-year, to be more responsive to its prospective ITA students.

Duration of the training period is another dimension that is important to students. 

Unemployed workers naturally want to reduce the duration of their unemployment. In 

addition, when they are receiving unemployment insurance, trade readjustment 

allowances, or another form of temporary income support, they have a strong incentive to 

conclude their training before the income support expires. Further, in tight labor markets, 

trainees are eager to complete training as soon as possible to take advantage of favorable 

employment conditions. Several respondents noted that proprietary schools often 

provided shorter, more intensive programs than their community college counterparts. 

Nevertheless, we found at least one community college in Metro Portland that is working 

with the One-Stop center to develop shorter-term training to meet the needs of ITA 

holders who are increasingly interested in shorter-term training so they could become 

employed quickly. 

The wider availability of auxiliary services for ITA holders, such as counseling, 

study skills workshops, and placement assistance, which we discussed in Chapter III, is 

another feature that distinguishes proprietary schools from community colleges. The 

proprietary schools commonly deliver such services directly to their students, while to 
V-5

take advantage of comparable services in a community college, students typically must 

seek out those services on their own. 

Recruiting Customers

Some training vendors, especially those who may be heavily dependent on ITA 

customers, are not passive players in the ITA process, simply waiting for customers to 

choose them from the eligible provider list. Instead, they may try to actively market their 

services to customers and staff within the One-Stop centers. 

Perhaps the most common technique that vendors use to recruit potential ITA 

holders is the reverse referral, whereby participants come into the One-Stop center 

seeking an ITA because they were referred there directly by a training vendor. This 

practice was common under JTPA, when most participants were slated to receive 

training. In this model, a vendor recruited an individual who was interested in training, 

through advertising, word-of-mouth, or other marketing techniques.2 The vendor then 

referred the person to the JTPA program with the expectation that the individual would 

be determined eligible for JTPA and sent back to the school for training. The ITA 

process under WIA introduces considerable uncertainty into this practice. If an

individual were referred back to a One-Stop center, that person would first have to 

progress through core and intensive services and be determined eligible for training, a 

less likely prospect than under JTPA. Second, the individuals would go through the ITA 

decision-making process, during which they might choose another vendor from the 

eligible provider list. While respondents in one local area think that these uncertainties 

would tend to diminish the use of reverse referral, we found some evidence that the 

practice is continuing. One vendor in the Atlanta Regional local areas, which makes 

reverse referrals extensively, was quite concerned about the risks involved. One of its 

officials wanted to place a staff member at the One-Stop center to help guide their 

reverse-referred people through the process to ensure that the school would not lose them. 

Vendors’ on-site presence at the One-Stop center can occur in other ways as well. 

At least two local sites invite vendors into their One-Stop centers to provide One-Stop 

customers in core and intensive services with labor market information about the 

occupations for which they provide training. In one site, training vendors also provide 

 

2 In some areas, vendors held outreach contracts from the Service Delivery Areas to find 

participants, determine their eligibility, and enroll them in their own training services.
V-6

direct services such as career exploration or job search workshops. Some center staff, 

however, find that these workshops are often thinly disguised recruiting efforts and they 

make efforts to ensure that the content remains legitimate. Elsewhere, the Atlanta 

Regional local areas invite vendors to their centers semi-annually to make formal 

presentations to the counseling staff about their services.

VENDORS’ RESPONSES TO THE ITA SYSTEM

Vendors face two major tasks in providing services under the ITA system, applying 

for eligibility and submitting performance data. With respect to the first of these, most of 

the vendors we talked with reported that the application process was fairly easy. While 

they still must fill out multi-page applications and identify all their programs, the absence 

of performance reporting requirements in 11 of the 13 states eased some of the 

controversies involved in creating the eligible provider list during initial eligibility. In 

fact, most vendors felt that the application process to get on the initial eligible provider 

list was fair and reasonable, although some found it to be burdensome.

The burden will become much greater under subsequent eligibility, when 

performance information is required. Reactions of the community colleges to this 

requirement are generally quite different from those of the proprietary schools. We found 

the former group to be, on average, quite distressed with the idea that they would need to 

provide performance data. For example, in SELACO, the local community college did 

not apply for the eligible provider list because of the performance requirement. In Texas, 

the number of programs dropped statewide by about 80% from initial eligibility, when no 

performance information was required, to subsequent eligibility. Nearly all of this drop 

came as a result of the community colleges’ refusing to participate. 

Three types of objections were raised by the community colleges. First, several of 

them indicated that their open admission policies would harm their performance 

compared to proprietary vendors with more selective admission policies. For example, in 

Baltimore, state law requires the Baltimore City Community College to admit all 

applicants regardless of their preparation. Consequently, it experiences a 50% dropout 

rate. Similarly, a community college in Cincinnati also has an open admission policy and 

a high dropout rate. Under these circumstances, these institutions felt, their performance 

results could be highly misleading.

The second principal argument we heard is that the costs of obtaining the 

performance information required of them by WIA are too high. For example, Indiana’s 
V-7

public postsecondary schools consider ITA customers to be an insignificant part of their 

revenue stream. With a budget of nearly a billion dollars, the schools are not eager to 

spend the resources to meet performance indicator requirements for the relatively few 

customers they might receive through ITAs. 

Finally, four-year colleges in several sites (Ohio and Pennsylvania) and the 

community colleges in several others (Greater Omaha and Indianapolis, among others) 

argued that gathering performance information related to employment outcomes was 

inconsistent with their educational role. These colleges view their primary mission as 

providing education, often leading to an associates degree or preparing students to 

transfer to four-year institutions, rather than providing job training. As such, they feel 

that a focus on employment outcomes distorts their sense of purpose.

States and local sites have made efforts to address these concerns in some cases. In 

Texas, for example, local marketing efforts were not successful in persuading many 

community colleges and technical schools to participate in the program beyond initial 

eligibility. The WIA administrative agency had to intervene with the state’s community 

college board to get these public institutions to participate on the eligible provider list for 

the first year of subsequent eligibility. However, these schools have already served 

notice that they may not re-apply in the second year of subsequent eligibility. Similar 

high-level efforts by state officials were mounted in Pennsylvania to persuade 

Pennsylvania State University to participate, as it is a major provider of training with 

satellite campuses throughout the state; no decisions had been made at the time of the site 

visit. In addition, in Pennsylvania, the community colleges in the Three Rivers WIB 

areas are also reluctant to provide performance information. But these schools are locally 

controlled, and the workforce development staff believe that the top city and county 

political leaders will exert sufficient political pressure upon the elected trustees who 

govern the community colleges to get the colleges to participate. 

In some other areas, the community colleges are still participating, even without 

such pressures. These colleges emphasize their economic development role or feel they 

have an obligation to educate or train residents who are not as well served by traditional 

four-year educational institutions. For example, the community college in Macomb-St. 

Clair feels that its community-service obligations outweigh any particular cost-benefit 

analysis that it might apply to ITA requirements. 
V-8

Proprietary institutions, on the other hand, expressed few reservations about 

supplying performance information. Those institutions that were heavily dependent on 

public funds were tracking performance information under JTPA and other programs, so 

that compliance with ITA requirements imposes no additional burden. Other proprietary 

schools that were less dependent on workforce development funds also indicated that 

they are already tracking performance for eligibility for Pell grants, accreditation, or state 

licensing, or because they are strongly market-driven. Others felt that the business from 

ITA was worth the cost of tracking performance. For example, in the Atlanta Regional 

local areas, the New Horizons computer school, a unit of the world’s largest independent 

computer-training school, pursues a corporate strategy to include ITA and othe r publiclyfunded students.3 School officials believe that JTPA was a good source of revenue and 

its students performed very well. They expect similar results under the ITA system.

RESHAPING THE TRAINING MARKETPLACE FROM JTPA

Structure of the Market

The prototypical ITA system seeks to restructure the training marketplace in 

several ways. To begin with, it seeks to dramatically increase the number of vendors 

from which customers can choose, improve quality and reduce costs through competition, 

and drive the system as a whole to better performance outcomes. Additionally, it shifts 

the fundamental market relationship from that between vendor and workforce agency to 

vendor and participant. Under JTPA, training vendors were service providers to the 

Service Delivery Areas and the customer relationship for training vendors was with the 

workforce development agency. While agencies were required to procure those services 

through competitive, arms-length procurements, there was often a close and ongoing 

relationship between agencies and vendors, especially for vendors with many JTPA 

trainees or in areas with few training providers. WIA, in contrast, changes the basic 

relationship. Under an ITA system, the LWIA functions largely as a neutral broker, 

qualifying credentials from vendors who then establish a customer relationship directly 

with the end customer.

However, while the structural transition in the customer relationship has occurred, 

evidence from the demonstration sites that the ITA system is having any substantial 

 

3 The level of effort to include publicly -funded trainees, however, varies by location in this 

franchised operation. The school in the Atlanta Regional local areas serves mostly dislocated workers, in 

part because of its location, which is far from low-income neighborhoods.
V-9

effect on the structure of the marketplace for training at this early stage is limited. As we 

noted in Chapter III, the customers—mostly low-income adults and dislocated workers—

are essentially the same as those trained under JTPA. Moreover, since many of the sites 

already eliminated many of their class-size training contracts in favor of individual 

referrals and vouchers, one fundamental element of the structural change—the customer 

relationship—had already occurred. Predominantly, local sites reported that most of their 

vendors from JTPA continue to provide service to the ITA programs. Only a few sites 

reported that they recruited a substantial number of new vendors that might increase 

customer choice. Vendors in the sites that had previous experience with customer choice, 

with one exception, reported that there is little real difference in providing training to 

JTPA and ITA customers. In some cases, our local respondents noted that the 

administrative relationships were precisely the same as they were under JTPA. 

The major difference that vendors are realizing in most sites is that they have fewer 

customers under WIA than they had under JTPA. To some extent, this is a problem of 

timing, because WIA only recently started and few customers have worked through the 

prior levels of services to get to ITA training. In other cases, there is an expectation of a 

permanent reduction in the number of trainees, because some LWIAs expect to have less 

money available for training than previously. Further, there is an expectation that 

effective core and intensive services will be successful in placing some percentage of 

customers in jobs, thus reducing the need for training investments. 

These factors reduce the aggregate demand for training and are thus likely to have 

some adverse effect on the supply of training. These adverse effects are most likely to 

fall on certain proprietary schools and community-based organizations that were most 

dependent on JTPA business. Some of these proprietary institutions are vulnerable to 

disruption under WIA, and even bankruptcy. Several sites noted that some of these 

schools and organizations have already closed or were on the verge of closing. At one 

site, these proprietary schools are responding by modifying their recruitment strategies to 

emphasize private-pay customers.

Dependency on workforce development funds is even more acute for communitybased organizations, which often played a substantial role in providing training by 

contract to economically disadvantaged youth and adults under JTPA. These 

organizations face greater difficulties under the ITA system. First, the presence of the 

ITA as the primary training vehicle reduces the level of contract training at most sites. 

Second, these organizations may have difficulty competing in the ITA marketplace 
V-10

because the performance measures for community-based organizations may compare 

unfavorably to other training institutions when customers choose schools. Since none of 

the states indicated that they had immediate plans to adjust performance to account for 

differences in participant characteristics, the CBOs’ emphasis on training lower-skilled 

adults whose outcomes tend be lower than other groups would make them show poorly in 

a simple comparison of performance. 

But even if they surmount the performance issue, these organizations are often 

inadequately capitalized and may have difficulty sustaining operations if they have an 

uneven flow of participants. In the Atlanta Regional local areas, planners noted that 

many community-based organizations lacked adequate capital and were already 

vulnerable to year-to-year shifts in funding under JTPA. Given customer choice in the 

ITA system, they could expect to endure additional periods with reduced cash flow. 

Several had already closed their doors. The results for community-based organizations 

thus appear quite uncertain.

Tuition Costs

While costs are relatively less important to individual customers, they are naturally 

quite important to the LWIAs, which, in most cases, have limited funds for training. As 

noted earlier in this chapter, there is little evidence that the ITA system has any impact on 

the tuition that vendors charge. Only one vendor, a truck driving school that was in fact 

quite dependent on ITA customers, reduced its tuition because of the ITA cap. Nor do 

ITAs appear to have any impact on the cost differential between public and private 

schools. Several respondents indicated that their community colleges had always charged 

much lower tuition than the proprietary schools, and the differential is the same under the 

ITA system. On the one hand, the lower tuition charged by community colleges enables 

LWIAs to provide more ITAs from this source with the same pot of money. On the other 

hand, among those LWIAs that provide extensive supportive services, the lower tuition at 

community colleges is offset to some degree by the longer duration of its programs, 

compared to proprietary schools, which implies that supportive services must be provided 

over a longer period of time. A longer duration increases the cost of supportive services 

to the point that, in at least one area, the administrators estimate that there is no net 
V-11

difference in the total costs between training an individual at a community college and at 

a proprietary school. 4

One area is trying to reduce the cost of training from all vendors. The Three Rivers 

WIB is using demonstration grant funds in an effort to increase competition among 

training vendors and drive costs down. Specifically, the WIB is working with a forprofit, Internet start-up company that is trying to create a bidding process on a web site so 

that public and private sector organizations seeking training services for their incumbent 

employees could aggregate their requests to help reduce the average cost of training. For 

example, a One-Stop center might need computer network training paid for by an ITA at 

the same time that a small business needs a similar course for one of its employees. The 

web site would bring the two requests together and seek a bid from a training provider 

that they expect would be lower than either organization could obtain on its own. The 

demonstration grant investment will help the start-up company test the viability of the 

concept and prepare for investor financing. The Local Board views this activity as a 

mechanism to leverage WIA funds to increase the efficiency of the local market for 

training, regardless of whether funds come from public or private sources.

SUMMARY

Congress intended that the ITA system would substantially revamp the training 

system and create a training marketplace. At this point, it is much too early to tell exactly 

what this new system will look like. Nonetheless, we observed a number of persistent 

elements in the relationship between training vendors and the public workforce 

development system in the demonstration sites as the system makes its transition from 

JTPA training to an ITA system. In the first place, because many of the sites had already 

made the transition from class-size training to individual referrals or vouchers, the basic 

relationship between the workforce development agency and the training vendors did not 

change significantly. Second, the demonstration sites are predominantly training the 

same types of participants, dislocated workers and low-income adults, as they did under 

JTPA. Third, at least under initial eligibility, the roster of vendors is largely the same as 

that which existed under JTPA. And finally, many local areas do not have sufficiently 

large labor markets to sustain competition among vendors.

 

4 In one state, we found that some vocational training programs at the community college must be 

self-supporting, so their cost structure may not differ as much from proprietary schools as it does where 

there are substantial tax subsidies to the program. 
V-12

Alongside the elements of continuity were a number of important changes. With 

the loss of contracts in those places that were still using class-size contract training, 

institutions that were heavily reliant on workforce development funds were facing 

potential trouble, especially if they were not adequately capitalized and able to withstand 

the more variable customer flow under the ITA system. Second, the ITA system, and 

especially the vendor reaction to its requirement for the submission of performance 

information, exacerbated the differences that long existed between public postsecondary 

institutions—chiefly community colleges—and proprietary schools. Some of the public 

colleges are threatening not to participate in the system under subsequent eligibility, 

either because they are unwilling to bear the cost of tracking certain performance 

information or because they are concerned that their performance outcomes will compare 

unfavorably to other schools that have different student characteristics or are not 

comparable in other ways. Proprietary schools, on the other hand, are very comfortable 

with the performance information requirements.

Thus, a number of factors are likely to reduce the likelihood of a competitive 

marketplace for training. If the public institutions do not apply to be eligible providers in 

certain areas, their absence will reduce customers’ training options considerably. Where 

public and private institutions now compete, the absence of the public schools would 

substantially dampen choice from a customer perspective. And even if no major players 

drop out, the differences among the various types of vendors may lead to segmented 

market conditions in which little actual competition occurs. 

Nevertheless, it is too early to draw firm conclusions about the likely structure of a 

mature ITA training market because there are still a number of key features of the system 

that remain to be implemented. First, the low enrollment of participants with ITAs at the 

demonstration sites at the time of our site visits made it difficult for our vendor 

respondents to comment on the system. This low number of participants may contribute 

to the reluctance of new vendors to enter the system. Second, with one exception, states 

had not yet entered the period of subsequently eligibility; as such, vendors for the most 

part had not yet been held to performance benchmarks of the sort mandated by WIA and 

did not yet need to comply with the full range of reporting requirements that will 

eventually be necessary. And finally, very few of the states had in place completed and 

fully automated consumer report systems that customers could use as a basic source of 

information. 
V-13

Until these components of the system are fully in place and vendors have had an 

opportunity to react to the full system, it is difficult to know what the final shape of the 

ITA training marketplace will be. This evaluation’s Final Report, to be based on another 

round of site visits that will be conducted in the summer and fall of 2001, should have 

much to say about the impact of these subsequent system developments.
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VI-1

VI. SUMMARY AND PRELIMINARY OBSERVATIONS

Our site visits to study the ITA/ETP demonstration grantees were conducted at a 

time when many of them were still developing key aspects of their systems. Moreover, 

for a variety of reasons—including fears of funding shortfalls, a strong economy that 

makes job placements relatively easy to obtain, One-Stop centers’ apprehension of 

authorizing training unless it was absolutely necessary, and the need to have customers 

go through core and intensive services before training could be offered—in some sites no 

more than a score of customers had been issued an ITA, out of hundreds of WIA adult 

and dislocated worker enrollees. Clearly, the systems we saw were for the most part very 

much a work in progress. At the same time, all sites had made substantial progress, both 

in developing policies to serve customers with an ITA and in establishing an eligible 

provider list and consumer report system.

CONTEXT

Their progress was facilitated because most were not starting their ITA system 

development from scratch when the ITA/ETP demonstration grants were awarded. In 

fact, almost all had moved sharply away from the exclusive use of contracted training in 

the waning years of JTPA and towards individual referral methods, and over one-half of 

them claimed previous experience with using vouchers for training, either as a CMA 

demonstration grantee or as part of some other pilot program. One-Stop implementation 

grants that they had received from DOL during the mid- to late-1990s also helped them 

establish the infrastructure that they needed to serve adult and dislocated worker 

customers in a WIA framework. 

Building on this framework, the grantees were using their demonstration funding in 

very different ways, which in some ways reflected the nature and extent of their prior 

progress. Their grant objectives ranged from the very broad (e.g., develop ITA policies, 

build a consumer report system) to the quite specific (e.g., develop a code of ethics for 

vendors). In general, grantees that specified broader goals were not as far along in 

ITA/ETP system development at the time their grant proposals were prepared. By 

contrast, those that specified narrower goals had many elements of their systems already 

in place and were looking to enhance or refine them in some way.

Grant objectives can also be categorized with respect to their major area of focus. 

The most common cluster of objectives related to efforts to build electronic consumer 
VI-2

report systems. Again, this was specified in either very broad and sweeping terms or 

with some narrow element of the CSR in mind (e.g., building a customer messaging 

system). Capacity building was another key objective, but again the specifics varied. 

One grantee wanted to hire counseling experts to work with participants and coach case 

managers; another wanted to develop a curriculum for a peer-managed workshop; others 

wanted to develop and deliver training workshops for staff or develop computer modules 

that staff could access as a resource. The third largest category of grant objectives related 

to developing or testing ITA policies. Again, the specifics varied. One grantee is 

working in conjunction with several other local areas in the state to test alternative ITA 

polices, as a way of gathering information about which ones might be most effective; by 

contrast, another was trying to reduce area-to-area variation in ITA policies by trying to 

facilitate coordination and joint policy development. Finally, some grantees were using 

their grant funds to develop fiscal or tracking software or to automate the training 

provider application process.

CUSTOMERS’ USE OF ITAS

All of the grantees had embraced the ITA model for providing training services and 

generally seemed enthusiastic about its possibilities for empowering customers. In fact, 

nearly all of them were planning on using ITAs for training adults and dislocated workers 

almost exclusively; only two expected to make regular use of contracted training for 

meeting the needs of special populations. However, several expected a sharp drop-off in 

the number of persons they would fund for training each year, citing what they felt was 

WIA’s “work first” emphasis and funding limitations caused by their needing to expend 

resources on developing their core and intensive service strategies.

Regardless of the customer volume that they anticipated, sites needed to develop 

policies to guide the way that customers move through the service levels and make 

training choices. With respect to the first of these, WIA’s emphasis on a hierarchy of 

services mandates that adults and dislocated workers participate in at least one core 

service and one intensive service without having their employment goals met, before 

training services can be considered. The legislation also requires that priority for training 

in the adult program be provided to public assistance recipients and other low-income 

individuals. Understanding how core and intensive services are structured, then, becomes 

key to knowing who accesses the ITA and under what circumstances.

The case-study sites varied quite a bit with respect to the policies and procedures 

that they established for this purpose. Some noted that customers whom the case 
VI-3

manager felt could obviously benefit from training were moved through core and 

intensive services quite quickly. In one case, for example, the core service might be a 

One-Stop orientation and the intensive service the development of the individual 

employment plan. Other sites had more stringent requirements before customers could 

move through to training—for example, by having case managers exhaust all reasonable 

possibilities that the customer might have transferable skills and/or requiring that 

customers spend at least several weeks in core and intensive services engaging in job 

search before training would be considered. Related to this distinction, some sites were 

prone to quickly move customers from self-service to staff-assisted core services, by 

adopting a staff interventionist approach; by contrast, others were much more inclined to

let customers engage in self-directed job search at their own pace. 

Another key difference across sites related to how intensive services were used as a 

prelude to training. Some sites felt that they could quickly (in core services) identify 

those who would need training services to meet their employment goals. Such 

individuals were placed in intensive services with the full expectation that they would 

shortly undertake training, so intensive services were focused on helping customers 

develop and refine their career and training plans. Other sites felt that intensive services 

represented another opportunity to identify transferable skills and improve job search 

strategies that might obviate the need for training altogether.

Despite these different general tendencies from one local area to the next, however, 

all the demonstration sites emphasized that guidelines were not meant to be followed 

rigidly and that they adopted a flexible approach to meeting customers’ needs. Thus, in 

almost every site customers could move from core and intensive services to training in a 

matter of a day or two, if circumstances warranted. Similarly, it was pointed out to us 

that dislocated workers could often be more self-sufficient in their job search and career 

planning, while low-income adults often floundered on their own and thus needed staff 

assistance sooner. It seems, then, that a key tenet of WIA that services should be 

customer driven and based on the individual’s own needs appears to be being followed. 

The customer focus is evident as well in the process that sites use to help customers 

make training choices. We identified three models that sites use under various 

circumstances. These are informed choice, which occupies a broad middle ground, and, 

at either extreme, directed choice and free choice. According to the informed choice 

model, One-Stop centers ensure that those authorized for training receive ample 

information, guidance, and assistance, so that they can make prudent choices with respect 
VI-4

to the occupation for which they want to be trained and the vendor who will provide it. 

Within this framework, customers are generally given fairly wide latitude in making their 

own choices. This was by far the predominant mode in the sites we visited. 

Operationally, it meant that customers would be required to undertake a comprehensive 

assessment of their skills and abilities and engage in extensive labor market and other 

research, before an ITA would be issued. Front-line staff play a key role in serving as 

“guides” or “facilitators,” striking what seemed to be an appropriate balance between 

lending the benefit of their expertise while not being overly directive. 

A key element that made the informed choice approach feasible was that 

assessment and research were required parts of the decision-making process. In addition 

to having participants undertake a comprehensive assessment and engage in labor market 

research, which were everywhere required, some sites required participants to conduct 

field research, such as by visiting several vendors and interviewing former trainees and 

employers who hire in that career area. Other sites required that customers attend 

workshops that are either given by case managers or are peer-managed (i.e., to promote a 

team approach to helping customers make choices). Sometimes also customers needed to 

submit a formal application, in which they identify the training field and vendor they 

have chosen and justify their decision on the basis of assessment results and the research 

they have conducted. As a consequence of following these steps to having their ITAs 

approved, customers would come to identify appropriate training choices on their own. 

By contrast, a “directed choice” approach was characterized by the case managers’ 

playing a much more directive role. Only one site used this model predominantly, 

although others would use it under special circumstances, as when customers seemed 

unable to make sense of their assessment results or were reluctant to make judgements 

based on the research they had conducted. In these instances, case managers could be 

quite emphatic in steering customers to the choices that the case manager thought best.

Finally, the third approach, a “free choice” model, was also used sparingly. 

According to this strategy, case managers would essentially give customers free reign to 

make training choices, so long as the training field was for an occupation in demand and 

the vendor appeared on the ETP list. No site used this approach predominantly. 

However, customers who knew exactly what training they wanted to undertake before 

entering the One-Stop center, and who could justify their choice, often had their request 

honored with little difficulty.
VI-5

Given the predominance of the informed choice model, then, our interviews and 

observations lead us to the conclusion that customers are effectively the decision-makers 

almost always. However, their choice is subject to certain limitations established by state 

and local policy. For example, in keeping with the WIA legislation, training can only be 

funded if it is for an occupation in demand. Some local areas met this requirement by 

drawing on lists developed by the state’s labor market information research unit. Other 

sites used locally-developed lists, and a few had no formal lists but instead relied on the 

judgement of the case managers. Typically, where there were such lists, exceptions could 

be made so long as a prospective trainee could present evidence that a job would be 

available once training was complete; however, a few local areas allowed no exceptions 

whatsoever.

Other restrictions related to dollar or time limits. Nearly all of the sites set a dollar 

cap on the amount of the ITA that would be funded, but these varied widely across sites, 

from a low of $1,700 to a high of $10,000. Tuition and fees, as well as books, uniform, 

and equipment, would normally be funded by the ITA, and supportive services would be 

provided from a separate pot of money. In keeping with WIA, trainees were typically 

expected to apply for a Pell grant, and amounts they received from that source were often 

applied to the cost of the training, with the ITA paying any balance due. Nearly all sites 

also had time limits on the duration of training that they would support, which they 

usually set at two years. Overwhelmingly, both dollar and time limits were imposed by 

local areas; although they were allowed to impose limits of their own, states generally felt 

that these decisions should be left as a local prerogative.

Even with these limits, sites could be investing a substantial amount on each 

trainee. For that reason, and also because performance accountability is so central to 

WIA, sites clearly had an interest in doing what they could to ensure that their ITA 

holders completed the training and obtained a well-paying job afterwards. Thus, all sites 

made provisions for keeping abreast of the trainee’s progress and attempted to address 

problems as they arose. Some sites were more proactive than others were, but virtually 

all maintained at least monthly contact with WIA participants in training. 

Given that their performance is publicly displayed as part of the consumer report 

system, vendors also have a clear stake in the trainee’s success, and thus they too played 

a part in monitoring the participant’s progress. Along these lines, proprietary schools—at 

least those that we visited as part of this study—seemed very attentive to students’ needs 

for extra assistance, and were aggressive in helping their students find jobs once the 
VI-6

training was completed. By contrast, although community colleges offered counseling 

and placement services, they were typically less proactive in their approach. 

DEVELOPING THE ETP LIST AND CONSUMER REPORT SYSTEM

A key element of the training system envisioned by WIA is for there to be clear 

accountability and strong information systems to support customer choice. The eligible 

training provider (ETP) list and consumer report system (CRS) constitute essential tools 

for these purposes. ITA holders can procure training services only from vendors who 

meet the eligibility guidelines imposed by states and local areas for inclusion on the ETP 

list. Information about the vendors’ performance should then be displayed in a consumer 

report system, along with whatever other information that might help support customers 

in their decision making. Developing the ETP list and consumer report system proved to 

be extraordinarily resource intensive. 

A key issue that states grappled with as they assembled the CRS was deciding 

whether only ITA-approved vendors should be included or whether it should include nonITA approved vendors as well. About half of the states adopted each approach. Those 

that were developing a restricted consumer report system emphasized the primary 

objective of supporting training customers in selecting a vendor; those that opted for the 

broader approach were giving priority to developing a resource for the universal customer 

in core services and making the broadest possible use of the resource they were 

developing. Using different logic, both also saw their approach as serving as an 

inducement for vendors to seek ITA eligibility. 

Regardless of the approach they took, sites were generally eager to widely 

publicize the ETP application process and have as many vendors apply for eligibility as 

possible. In some cases, states took the lead role, such as by sending an ETP application 

packet to all state-certified training vendors in the state. In other states, local areas took 

the lead role, such as by communicating with their former JTPA providers or holding 

informational sessions in the community. Most states attempted to automate the 

application process, both to make it easier for vendors to apply and also to expedite the 

state’s and local areas’ roles in processing applications and entering the data into an 

electronic ETP listing. Those states without an electronic application found the process 

substantially more burdensome.

Only two states, Missouri and Texas, set performance requirements for initial 

eligibility. The others dispensed with such requirements, because they felt ill equipped to 
VI-7

make decisions regarding performance benchmarks at such an early stage. In general, 

vendors were not even required to submit performance data as part of their initial 

application. States felt that doing otherwise would impose a substantial burden on 

vendors that they were not yet prepared to meet.

In keeping with the legislation, the approval process for initial eligibility basically 

worked the same way in all the sites we visited—local areas would first review the 

applications, make a judgement of whether the application should be approved, and then 

pass the application on to the state, along with the local area’s recommendation, for final 

disposition. The one difference was that some states had vendors submit their 

applications directly to the local areas, while other states had vendors submit their 

applications to a central state clearinghouse, which then forwarded the applications to the 

local areas for their review. The latter approach was viewed as easier for vendors, who 

would need to submit just one application for each of its programs rather than multiple 

applications to multiple local areas throughout the state; it also standardized the 

application process somewhat.

Regardless, a concern that local areas expressed was having a vendor’s application 

for eligibility denied by one local area but approved by an adjacent one. Given that ITA 

holders can hypothetically choose any vendor on the state list, presumably a trainee could 

select a vendor that the local area funding the ITA had disapproved. Several of the casestudy sites were attempting to develop a regional approach to ETP review to eliminate 

this possibility. The case managers in another site admitted that they could not envision 

authorizing an ITA if the customer had selected a vendor that the local area had not 

approved, except under exceptional circumstances.

Another concern was that many states anticipated a sharp drop in the number of 

vendors who were approved once subsequent eligibility began. As mentioned, only two 

states imposed performance requirements for initial eligibility, deliberately with the 

thought that they wanted as many vendors to apply as possible. Similarly, few reporting 

requirements were imposed, beyond asking the vendors to provide basic information 

about each of their programs, such as the duration of training and its costs. But, for 

subsequent eligibility, vendors must be prepared to begin submitting performance 

information about their programs, relating to the completion rates and employment 

outcomes of trainees, including those that were WIA funded and others. Many vendors, 

especially community colleges, have balked at these requirements. They viewed the time 

and effort necessary to assemble the necessary information as not worth the trouble, 
VI-8

given that they anticipate serving relatively few WIA-funded trainees. As openenrollment institutions serving diverse community needs, some community colleges also 

feel that their measured performance could misrepresent their actual success, given that 

some of their non-ITA enrollees might lack adequate preparation for training or others 

might not have employment objectives in mind. The only state in our sample that had 

entered subsequent eligibility at the time our site visits were conducted saw an 80% drop 

in vendors’ applications, primarily for these reasons.

Another reason why the ETP list under subsequent eligibility might be appreciably 

smaller than the initial list is that all states will presumably impose required performance 

benchmarks for subsequent eligibility, while only two states did so for initial eligibility. 

Only four states—Texas, Missouri, Pennsylvania, and Maryland—in our sample had 

decided, even tentatively, what their performance requirements would be for subsequent 

eligibility. Nonetheless, all were grappling with where to strike the balance between 

setting the minimum requirements high enough to reflect their high expectations, while 

not setting them so high as to exclude so many vendors that participant choice is 

seriously compromised. 

Definitional issues were also presenting serious conceptual hurdles. For example, 

even at the point of initial eligibility states needed to make clear what would constitute a 

“program” for purposes of the ETP list. Thereafter, as they attempted to measure 

performance for subsequent eligibility, they needed to decide how key terms would be 

defined, such as who counts as enrolled and what constitutes a completion. Given the 

fact that many community college enrollees may take variable sequences of courses with 

different employment and other objectives in mind, states were generally allowing 

vendors to self-define programs and some were counting as enrollees only those who 

declared their intention to complete the entire sequence of courses that made up the 

program, with employment as the intended objective. 

Amassing the data to measure performance, however the measures were defined, 

also will prove challenging. In keeping with WIA requirements, states were planning on 

relying heavily on using Unemployment Insurance wage records for measuring outcomes 

that were employment related. Thus, vendors would forward the social security numbers 

of enrollees to the relevant state entity, who would then conduct the UI matching on the 

vendors’ behalf. This approach seemed to make the most sense from the standpoint of 

ensuring completeness, reliability, and comparability. However, the well-known 

limitations of UI data (e.g., its inability to capture employment in non-covered sectors 
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and, without inter-state agreements, in other states) have led at least two states to allow 

vendors to supplement UI results with employment data from their own sources (e.g., 

surveys). Other states were still weighing this possibility.

In contrast to employment outcomes, where the states will bear most of the burden 

in data collection on the vendors’ behalf, most states are expecting vendors to supply data 

on their programs’ completion rates. Connecticut, however, is considering computing 

even these rates for vendors, if the vendors will forward to the state the vendors’ 

enrollment database.

Given the complications that needed to be resolved, at the time of our site visits 

only a few states’ systems had any information about vendors’ performance. Clearly, 

much work remains to be accomplished for the consumer report systems to fulfill their 

function of providing an important resource to guide customer choice. 

VENDORS’ REACTION

In the local areas we studied nearly all training vendors certified as eligible for ETP 

purposes are either community colleges or proprietary schools. These two types of 

institutions have very different missions and define themselves very differently. The 

former have traditionally filled an important role in providing training under JTPA, 

because of the breadth of their offerings and generally low tuition, and it is expected that 

they will be similarly important under WIA. However, many are balking at the eligibility 

requirements that WIA imposes, especially their need to submit performance information 

about their programs. In their view, the low volume of ITA-funded trainees that they 

anticipate does not warrant the time and expense that such a requirement would entail. 

They also fear that their performance would be inaccurately characterized, given the mix 

of customers that many of them serve. Finally, many of them view themselves as 

educational institutions, and not employment and training institutions, and thus believe 

that the CRS’s emphasis on employment outcomes distorts what they see as their true 

purpose.

By contrast, the proprietary schools whose representatives we met characterized 

themselves as being active in the marketplace and highly performance driven. For their 

own purposes, or to meet other state or federal certification requirements, these schools 

had been accustomed to collecting and reporting performance data and saw no difficulty 

with doing so for ETP purposes. They were also highly adaptable and flexible, 
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modifying course content, starting times, and training durations to better appeal to 

potential trainees. 

Community-based institutions constitute a third group of potential vendors. While 

we did not visit with any community-based organizations that provide ITA training,

Local Board and One-Stop staff noted that many of these organizations provided training 

to economically disadvantaged adults under JTPA, but are not likely to be successful 

under an ITA system because of their traditionally narrow customer base. In addition, 

their frequent reliance on contract training puts them at risk of losing more customers 

than they might gain in a competitive marketplace. Further, they are usually thinly 

capitalized and are likely to have difficulty coping with an irregular flow of ITA students. 

PRELIMINARY CONCLUSIONS

The above discussion makes clear that the full ITA and consumer report systems 

envisioned by WIA were still very much under development at the time our site visits 

were conducted. Our upcoming second round of site visits, to be conducted in the 

summer and fall of 2001, will thus offer the important opportunity to view these systems 

as they have matured. At this point, however, some preliminary conclusions can be 

drawn.

1. State and local-area flexibility seems to be embedded in the systems that are 

developing. One of the key tenets of WIA is to devolve decision-making 

authority to the states and local areas, from the federal level. The implications 

of this principle seem clearly to be evidence in the sites we visited. Thus, 

although there are obvious broad similarities in the systems that are developing, 

states and local areas are making unique decisions regarding key features of 

ITA policies. Thus, dollar caps vary widely and the procedures guiding 

customer choice take on a local flavor. Similarly, ETP systems and procedures 

are unique, including with respect to how key terms are defined, what 

performance benchmarks are required of vendors, and what consumer report 

systems look like from the customers’ perspective.

2. That flexibility, although clearly embraced by states and local areas as a good 

thing, is causing some confusion and uncertainty at this early stage. Thus, 

some local areas are unsure exactly what their policies and systems should look 

like. In light of this uncertainty, more peer-to-peer exchanges would be highly 

valued, so that sites could share ideas and examples.

3. Overall, there is likely to be a substantial drop-off in the number of persons 

entering training, at least in WIA’s first full year of implementation. This dropoff will come about for a variety of reasons, including a strong economy that 

has made job opportunities plentiful, competing priorities for using scarce WIA 

funds, and case managers’ reluctance to authorize training unless it is 
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absolutely necessary. In the coming months, sites will need to reach an 

equilibrium that they think best balances the competing aspects of their 

mission, from providing job search services for the universal customer, on the 

one hand, to providing needed training services to those with poor skills, on the 

other. 

4. Sites are maintaining a strong customer focus in the way they approach WIA’s 

three service levels. Despite the reluctance in some cases to authorize training 

unless it is absolutely necessary, in general we observed that sites are highly 

flexible in their approach to customer services. Thus, although sites have 

guidelines for how customers should move through the service levels, it was 

apparent that those guidelines were not meant to be followed rigidly and that 

customers’ obvious needs were taking precedence.

5. Informed customer choice is clearly apparent in the way that sites are working 

with customers to help them select training programs and vendors. WIA’s 

emphasis that customer choice should be paramount has clearly been taken to 

heart. Thus, customers are generally given the opportunity to make training 

choices that seem right to them. At the same time, this choice is structured 

within a framework that requires that customers undertake a careful assessment 

of their skills and abilities and conduct extensive labor market and other 

research. To this degree, customers are making choices only after being 

exposed to a range of good information. 

6. Front-line staff are generally playing roles that support informed choice. In 

most local areas that we visited, case managers were playing the role of 

“facilitators,” and were lending the benefit of their expertise without being 

overly directive. To this degree, customer empowerment was being promoted. 

Given that many sites had moved away from contract training in JTPA’s 

waning years, and, in some cases, had previous experience with vouchers, case 

managers often felt that operating under an ITA system was not that much 

different from what they were accustomed to.

7. The underdeveloped state of most consumer report systems has meant that firm 

data on vendor performance has not been one of the sources that most 

customers have been using in making their training decisions. Moreover, given 

the difficulties that lie ahead, with respect to data collection and data 

management, it will likely be some time before consumer report systems are 

reasonably populated with information about vendors’ performance. 

8. Incentives for community colleges to participate in the ETP system need to be 

established. Proprietary schools as a whole have been very agreeable to the 

requirements that the eligibility process entails. Community colleges, by 

contrast, view these requirements as not worth the effort, given the few ITA 

customers that they anticipate serving, and their focus as educational 

institutions. Given the important role that these institutions play in giving ITA 

holders meaningful choice, sites need to develop strategies to keep community 

colleges as active players in the training marketplace.
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9. The ITA/ETP process is presenting substantial challenges to training vendors 

that relied heavily on workforce development funding under JTPA. Reliant for 

so long on contract training for serving special populations, these organizations

are finding that their customer flow has been gravely interrupted since the 

enactment of WIA. This challenge has fallen especially heavily on communitybased institutions. Without an alternative customer base, many of these 

institutions are facing insolvency. Their absence will represent a substantial 

loss to their communities.

10. Processing vendors’ applications and developing the consumer report system 

are extraordinarily difficult and resource-intensive undertakings. In light of 

this, several grantees noted how fortunate they consider themselves to be in 

having been selected to participate in this demonstration, as it has provided 

them with access to special funds for system development that otherwise would 

have needed to come from their regular WIA formula allocation. This 

observation speaks to the difficulty that non-grantee states may be encountering 

with system development, and also for the need for states and local areas to 

develop systems that, once developed, can be sustained at minimal cost.