WORKFORCE 

INNOVATION AND 

OPPORTUNITY ACT

Information on 

Planned Changes to 

State Performance 

Reporting and 

Related Challenges

Report to Congressional Committees

March 2016

GAO-16-287

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-287, a report to 

congressional committees

March 2016

WORKFORCE INNOVATION AND 

OPPORTUNITY ACT

Information on Planned Changes to State 

Performance Reporting and Related Challenges

Why GAO Did This Study

Enacted in 2014, the Workforce 

Innovation and Opportunity Act brought 

numerous changes to existing federal 

employment and training programs, 

including requiring DOL and Education

to implement a common performance 

accountability system across the six 

WIOA-designated core programs.

WIOA includes a provision for GAO to 

issue an interim and final report on 

issues related to job training databases 

and data exchange agreements. This 

final report addresses (1) changes 

selected states plan to make in how 

they collect and report performance 

information for core programs; (2) 

challenges these states face related to 

performance reporting and how they 

might be addressed; and (3) whether 

these states have reported breaches to 

core program data systems and what 

practices they have to safeguard 

personal information.

GAO reviewed relevant federal laws, 

regulations, and policy guidance; and 

obtained information on the efforts 

under way in three states (Illinois, New 

Hampshire, and Texas) selected in 

part based on variation in level of

experience with sharing data across 

programs. The views of these officials

provide in-depth examples but are not 

generalizable to all states. GAO also 

interviewed DOL and Education 

officials, including selected DOL 

regional officials and Education state 

liaisons and area coordinators to 

obtain perspectives on more states.

GAO makes no recommendations in 

this report. In its comments on a draft 

of this report, DOL highlighted its 

efforts with Education to promote a 

unified vision of performance 

accountability.

What GAO Found

To implement the Workforce Innovation and Opportunity Act (WIOA), the 2014 

law governing the nation’s employment and training programs, the three states 

GAO visited are considering performance reporting changes such as integrating 

data systems and using new data sources. GAO selected states with varying 

levels of experience sharing data across programs. According to the 

Departments of Education (Education) and Labor (DOL), WIOA is intended, in 

part, to improve the consistency of states’ performance reporting compared to 

reporting under the law it replaced, the Workforce Investment Act of 1998. For six 

core DOL and Education programs, WIOA establishes common indicators of 

performance in areas such as employment and earnings, and encourages states 

to integrate data systems related to these indicators. In the states GAO visited—

Illinois, New Hampshire, and Texas—efforts to integrate data systems varied. For 

example, Texas is consolidating programs in one agency and building an 

integrated data system and Illinois is discussing integration options across the 

four agencies housing its programs. Officials in all three states expect changes in 

how they collect and report performance information. Though specific reporting 

requirements are not yet final, core programs—especially those administered by 

Education—face substantial changes. For example, Education programs in these 

states are exploring new ways to collect earnings data, such as adding survey 

questions or obtaining greater access to unemployment insurance wage records.

Program officials in the three states GAO visited identified challenges to WIOA 

performance reporting, including:

• Limited guidance. Officials in all three states said early implementation was

slowed because WIOA regulations are not yet final and certain details about 

performance reporting are not yet resolved. In the interim, DOL and 

Education have offered states additional guidance.

• Cost and complexity of integrating data systems. Officials in Illinois and 

New Hampshire said that resource constraints pose challenges to integrating 

data systems. Among efforts to help defray integration costs, DOL and 

Education have sought additional federal funding for states.

• Data quality concerns. Missing participant data may continue to affect the 

quality of information states report to federal agencies. For example, some 

states reported using participant surveys to collect employment data due to 

challenges with state privacy laws. In addition, federal law generally allows 

participants to opt out of providing Social Security numbers (SSNs). Officials 

in the states GAO visited said many participants in one of the Educationadministered programs do not provide SSNs, making it harder to match data 

to track their outcomes and participation in other programs.

Officials in the three states GAO visited reported no intrusions into their data 

systems in recent years. Officials in two states did report other occasional 

security breaches that may have resulted in inappropriate exposure of personally 

identifiable information for small numbers of people in limited circumstances; for 

example, emails that included participant SSNs. Officials in all three states

reported taking steps to limit and protect the participant information they collect, 

such as monitoring and controlling data access.

View GAO-16-287. For more information, 

contact Andrew Sherrill at (202) 512-7215 or 

sherrilla@gao.gov.
Page i GAO-16-287 WIOA State Performance Data

Letter 1

Background 4

Officials in Selected States Anticipate Changes in How They 

Collect and Report Performance Data, Such As Integrating 

Data Systems, Though the Full Extent is Not Yet Known 9

Limited Information About Reporting Requirements and the 

Difficulty of Integrating Data Systems Challenge Implementation 

in Selected States 24

Three States GAO Visited Reported No Intrusions into their Data 

Systems and that they Take Steps to Limit and Safeguard 

Personal Information Collected 34

Agency Comments 38

Appendix I Comments from the U.S. Department of Labor 40

Appendix II GAO Contact and Staff Acknowledgments 42

Related GAO Products 43

Tables

Table 1: Workforce Innovation and Opportunity Act (WIOA) Core 

Programs 4

Table 2: Workforce Innovation and Opportunity Act (WIOA) 

Common Indicators of Performance 5

Table 3: Summary Information on Case Management Data 

Systems in Illinois, New Hampshire, and Texas 10

Figures

Figure 1: Requirements for Common Performance Accountability 

System and Related Time Frames 6

Figure 2: General Flow of Performance Outcome Data to Federal 

Agencies 8

Figure 3: Models of Potential Data System Integration for 

Performance Reporting 15

Contents
Page ii GAO-16-287 WIOA State Performance Data

Figure 4: Current and Planned Integration of Core Program Data 

Systems and Performance Reporting at the Texas 

Workforce Commission (TWC) 18

Abbreviations

CREC Center for Regional Economic Competitiveness

DOL Department of Labor

ETA Employment and Training Administration

ETP Eligible Training Provider

FEDES Federal Employment Data Exchange System

HHS Department of Health and Human Services

IT Information technology

LMI Labor Market Information

NDNH National Directory of New Hires

OCTAE Office of Career, Technical, and Adult Education

PII Personally identifiable information

RSA Rehabilitation Services Administration

SSN Social Security number

TEGL Training and Employment Guidance Letter

TWC Texas Workforce Commission

UI Unemployment Insurance

VR State Vocational Rehabilitation Services

WIA Workforce Investment Act of 1998

WIOA Workforce Innovation and Opportunity Act

WRIS Wage Record Interchange System

WRIS2 Wage Record Interchange System 2

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

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

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

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-287 WIOA State Performance Data

441 G St. N.W.

Washington, DC 20548

March 7, 2016

The Honorable Lamar Alexander

Chairman

The Honorable Patty Murray

Ranking Member

Committee on Health, Education, Labor, and Pensions

United States Senate

The Honorable John P. Kline

Chairman

The Honorable Robert C. “Bobby” Scott

Ranking Member

Committee on Education and the Workforce

House of Representatives

In 2014, the Workforce Innovation and Opportunity Act (WIOA) brought 

changes to the programs that create a foundation for the nation’s 

employment and job training system.1 WIOA requires that the 

Departments of Labor (DOL) and Education (Education) collaborate to 

implement a common performance accountability system for six core 

programs, which the agencies note is a historic opportunity to align 

definitions, streamline performance indicators, and integrate reporting 

across programs. These core programs, which DOL and Education 

administer primarily through grants to state agencies, are: Title I Adult, 

Title I Dislocated Worker, Title I Youth, Wagner-Peyser Employment 

Services (Wagner-Peyser), Adult Education and Family Literacy Act 

(Adult Education), and State Vocational Rehabilitation Services 

(Vocational Rehabilitation or VR).2 WIOA establishes six performance 

indicators for these core programs related to participants’ employment 

status, earnings, and skills gains, and for effectiveness in serving 

employers.3 Under the prior law, the Workforce Investment Act of 1998 

 1 Pub. L. No. 113-128, 128 Stat. 1425.

2 When we use the term “core,” we are referring to the programs that were eventually 

labeled core under WIOA. We generally refer to Title I Adult, Dislocated Worker, and 

Youth programs together as Title I programs.

3 Pub. L. No. 113-128, § 116(b), 128 Stat. 1425, 1471 (2014).

Letter
Page 2 GAO-16-287 WIOA State Performance Data

(WIA), all six programs reported on performance related to employment 

and most reported on performance related to earnings. However, 

indicators varied considerably across several of the programs. WIOA’s 

establishment of uniform indicators of performance across all six core 

programs represents a noticeable change.

Section 505 of WIOA includes a provision for GAO to issue an interim and 

final report on various issues related to federal and state databases and 

data exchange agreements containing job training information relevant to 

WIOA.4 We provided an interim briefing on July 22, 2015, focusing on the 

current state of performance reporting for the core programs and the data 

systems and exchange agreements in place at the federal level, and 

issued the briefing publicly on September 23, 2015.5 In this final report, 

we focus on performance reporting, data systems, and related issues for 

core programs at the state level by examining (1) changes selected states 

plan to make in how they collect and report performance information for 

core programs; (2) challenges core programs in selected states face 

related to performance reporting and how they might be addressed; and 

(3) whether selected states have reported breaches to core program data 

systems and what practices they have to safeguard personal information.

In conducting this work, we focused on collecting detailed information on 

the practices and perspectives of the six core WIOA programs at the state 

level. We conducted site visits and interviewed program officials in three 

states—Illinois, New Hampshire, and Texas—selected to capture 

variation in level of experience with sharing data, geographic location, 

and population size. We considered data sharing experience based 

largely on the extent to which states have previously matched individuals’

records across education and workforce sectors and the 

recommendations of knowledgeable officials.6 The views of officials in the 

three selected states cannot be generalized to all states, but instead 

provide in-depth case studies at the state level. To obtain supplementary 

 4 We generally use the term data systems instead of databases to broadly capture data 

collection and storage.

5 GAO, Workforce Innovation and Opportunity Act: Performance Reporting and Related 

Challenges, GAO-15-764R (Washington, D.C.: September 23, 2015).

6 For information about states’ experiences with sharing data, see GAO, Education and 

Workforce Data: Challenges in Matching Student and Worker Information Raise Concerns 

about Longitudinal Data Systems, GAO-15-27 (Washington, D.C.: November 19, 2014).
Page 3 GAO-16-287 WIOA State Performance Data

information covering additional states, we interviewed selected DOL and 

Education regional officials, state liaisons, and area coordinators, who 

work with the core programs in multiple states.7 We reviewed relevant 

federal laws, regulations, and guidance, and interviewed officials 

responsible for administering the programs in DOL’s Employment and 

Training Administration (ETA) and Education’s Rehabilitation Services 

Administration (RSA) and Office of Career, Technical, and Adult 

Education (OCTAE), as well as other knowledgeable individuals. Through 

our interviews, we obtained information on key changes and challenges 

states are facing in the early stages of implementing the requirements of 

WIOA, among other things. We also obtained information on the data 

systems and security practices the three states have in place, but we did 

not evaluate the quality or sufficiency of their practices, audit their 

information technology systems, or investigate specific security breaches.

We conducted this performance audit from June 2015 to March 2016 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 7 We spoke to DOL officials from each of the 3 regions that did not include our selected 

states (covering a total of 22 states and 4 outlying areas); 5 Rehabilitation Services 

Administration state liaisons for the Vocational Rehabilitation program who worked with 

the greatest number of states but not one of our selected states (covering a total of 15 

states and 2 outlying areas); and Office of Career, Technical, and Adult Education area 

coordinators for the Adult Education program who work with states regionally (the 

coordinators we spoke with represented the perspectives of all states and outlying areas 

in the program’s 5 geographic areas).
Page 4 GAO-16-287 WIOA State Performance Data

Among other things, WIOA requires that DOL and Education collaborate 

to implement a common performance accountability system for the six 

core programs identified in the law (see table 1).

Table 1: Workforce Innovation and Opportunity Act (WIOA) Core Programs

Administered by Department of Labor 

(DOL):a

Title I Adult Provides training and services, such as occupational skills training, career counseling,

and job searches, to adults ages 18 years or older

Title I Dislocated Worker Provides the same services as the Title I Adult program for those who, generally, among 

other criteria, anticipate or have been terminated or laid-off or who were self-employed

Title I Youth Provides various services, including educational supports, occupational skills training, 

counseling, and paid and unpaid work experiences, generally to low-income youths who 

are facing one or more barriers to employment

Wagner-Peyser Employment Services Provides employment services, including job searches and placement assistance, and 

referrals to employers

Administered by Department of 

Education (Education):b

Adult Education and Family Literacy Act Generally assists adults in becoming literate or achieving proficiency in English, obtaining 

the knowledge and skills necessary for employment and self-sufficiency and to assist in 

their children’s educational development, and completing a secondary school education

State Vocational Rehabilitation Services Provides services such as counseling, job training, and job search assistance, related to 

the employment of people with disabilities

Source: GAO analysis of relevant federal law. | GAO-16-287

a DOL’s Employment and Training Administration (ETA) administers these programs and oversees 

their implementation, which is carried out by state workforce agencies and local workforce 

development boards. The local board selects the entities that will operate American Job Centers 

(formerly called one-stop centers) to provide services.

b Education’s Office of Career, Technical, and Adult Education (OCTAE) provides grants to states, 

which in turn distribute most of the federal funds to local adult education providers. The local provider 

network includes local educational agencies, community colleges, community-based organizations, 

and volunteer literacy organizations. Education’s Rehabilitation Services Administration (RSA) 

provides grants to states to administer the Vocational Rehabilitation program. Many states have 

separate agencies serving blind or visually impaired individuals in addition to agencies that serve all 

other individuals with disabilities. In addition, states vary in terms of the organizational positioning of 

the program, with the program being housed in education, workforce, social service, or disability 

program agencies, or elsewhere.

Background
Page 5 GAO-16-287 WIOA State Performance Data

For the core programs, WIOA establishes six performance indicators on 

which states must report, with some exceptions (see table 2).8

Table 2: Workforce Innovation and Opportunity Act (WIOA) Common Indicators of Performance

Employment in Second Quarter After 

Exit

Percentage of program participants who are in unsubsidized employment during the 

second quarter after exit from the program.

Employment in Fourth Quarter After 

Exit

Percentage of program participants in unsubsidized employment during the fourth quarter 

after exit from the program.

Earnings Median earnings of program participants in unsubsidized employment during the second 

quarter after exit from the program.

Skill Gains in Education or Training 

Programs

Percentage of program participants who, during a program year, are in an education or 

training program leading to a recognized postsecondary credential or employment and 

who are achieving measurable skill gains toward such a credential or employment.

Attainment of a Credential or Diploma Percentage of program participants obtaining a recognized postsecondary credential, or a 

secondary school diploma or its recognized equivalent, during participation in or within 1 

year of exit from the program.

Effectiveness in Serving Employers Indicators of effectiveness in serving employers, to be developed by the Secretaries of 

Education and Labor.

Source: GAO analysis of Pub. L. No. 113-128, § 116(b), 128 Stat. 1425, 1471 (2014). | GAO-16-287

As shown in figure 1, programs are required to begin using the WIOA 

common performance indicators as of July 2016, two years after the law 

was enacted and just under six months after final regulations are due. 

DOL and Education officials are responsible for providing technical 

assistance and imposing sanctions on states that do not meet 

performance expectations. DOL and Education issued joint proposed 

regulations in April 2015 that, among other things, covered WIOA 

performance reporting, and in July 2015, issued a joint proposed 

performance reporting template. DOL issued additional proposed 

reporting details in September 2015. Final regulations, reflecting any 

changes based on public comments and agency review, will, among other 

things, form the basis for states’ implementation of WIOA.

 8 Pub. L. No. 113-128, § 116(b), 128 Stat. 1425, 1471 (2014). For the Title I Youth 

program, the two employment measures include participants who are in education or 

training in addition to those in unsubsidized employment. Additionally, Wagner-Peyser 

Employment Services is not required to report on credential attainment or measurable skill 

gains.
Page 6 GAO-16-287 WIOA State Performance Data

Figure 1: Requirements for Common Performance Accountability System and Related Time Frames

WIOA emphasizes the importance of a comprehensive system that 

provides integrated, seamless services to all job seekers and workers and 

effective strategies that meet employers’ workforce needs. DOL and 

Education note that the development of integrated data systems will allow 

for unified and streamlined participant intake (i.e., application and 

registration), case management, and service delivery; minimize the 

duplication of data; ensure consistently defined and applied data 

elements; facilitate compliance with reporting requirements; and provide 

meaningful information about core program participation to inform 

operations.

WIOA also requires states to use quarterly wage records, consistent with 

state law, to measure program performance (e.g., Unemployment 

Insurance (UI) wage records).9 Prior to WIOA, coordination among DOLadministered programs to share wage records for performance reporting 

was common, but access to and use of these data were less common for 

Education-administered programs. To help states obtain the data needed 

for performance reporting, particularly when participants are employed in 

 9 According to the joint proposed regulations issued by DOL and Education, wage records 

would include an individual’s wage amount, an employee identifier (Social Security 

number), and an employer identifier (name, address, state, and Federal employer 

identification number). According to DOL officials, although federal laws and regulations 

influence access to UI wage records, states are the owners of these data and can create 

laws and regulations that can limit or expand access to the data.

Data Integration, Access, 

and Security
Page 7 GAO-16-287 WIOA State Performance Data

another state or with the federal government, DOL currently funds three 

data exchange systems that allow agencies reporting on performance to 

access other states’ UI wage records or federal employment data: Wage 

Record Interchange System (WRIS); Wage Record Interchange System 2 

(WRIS2); and Federal Employment Data Exchange System (FEDES).10

States compile and submit program performance data to federal systems 

either in aggregate or by individual participant, depending on the 

program.

Personally identifiable information (PII) for program participants, such as 

names, addresses and Social Security numbers (SSNs), among other 

things, is often shared between entities to link individual records across 

data systems and to collect program outcome information from state 

education and employment and training agencies.11 Because security 

breaches involving PII can be hazardous to individuals and organizations, 

protecting the privacy of sensitive information on program participants is a 

concern for DOL, Education, and its state and local partners.12 The Fair 

Information Practice Principles outline a set of eight key principles for 

protecting PII, including limiting the collection of personal information, 

disclosing how collected information will be used and obtaining consent 

from the individual, and protecting collected information with reasonable 

security safeguards against risks such as loss or unauthorized access. 

The eight principles are transparency, individual participation, purposes 

 10 WRIS allows the exchange of state wage record data for participants in workforce 

programs, WRIS2 allows the exchange of state wage record data for participants in 

related programs like VR, and FEDES allows for the exchange of data for certain federal 

employees. For more information, see GAO-15-764R.

11 Personally identifiable information refers to any information about an individual 

maintained by an agency, including (1) any information that can be used to distinguish or 

trace an individual’s identity, such as name, SSN, date and place of birth, mother’s 

maiden name, or biometric records; and (2) any other information that is linked or linkable 

to an individual, such as medical, educational, financial, and employment information.

12 The term “data breach” generally refers to the unauthorized or unintentional exposure, 

disclosure, or loss of sensitive information, including PII. GAO, Information Security: 

Agency Responses to Breaches of Personally Identifiable Information Need to Be More 

Consistent, GAO-14-34 (Washington, D.C.: December 9, 2013).
Page 8 GAO-16-287 WIOA State Performance Data

specification, data minimization, use limitation, data quality and integrity, 

security, and accountability and auditing.13

While the performance reporting process is broadly similar across states, 

data system administration, the methods used to collect participant 

outcome data, and other specific practices vary by state and program. As 

we have reported previously, to fulfill program performance reporting 

requirements, state agencies generally collect participant identification 

and outcome data from local agencies and other sources, and then send 

performance reports to federal agencies (see fig. 2).14

Figure 2: General Flow of Performance Outcome Data to Federal Agencies

a There may be some differences in the information flow for the State Vocational Rehabilitation 

Services program, according to Department of Education officials.

 13 The Fair Information Practice Principles are cited in The White House, National 

Strategy for Trusted Identities in Cyberspace: Enhancing Online Choice, Efficiency, 

Security, and Privacy (Washington, D.C.: April 2011). According to the report, the Fair 

Information Practice Principles are at the core of the Privacy Act of 1974 and are mirrored 

in the laws of many U.S. states, as well as in those of many foreign nations and 

international organizations.

14 For more information, see GAO-15-764R and GAO, Workforce Investment Act: DOL 

Should Do More to Improve the Quality of Participant Data, GAO-14-4 (Washington, D.C.: 

December 2, 2013).

Performance Reporting 

Process Prior to WIOA
Page 9 GAO-16-287 WIOA State Performance Data

To store participant data used for federal performance reporting, as well 

as for other program management purposes, each WIOA core program in 

the states we visited has its own case management data system (see 

table 3). Some of these systems were developed by the respective state 

or program and others were purchased from vendors. These data 

systems are used for case and program management and to compile 

program data used for federal performance reporting. The systems store 

participant information, such as personal identification; track program 

services, such as training received; and, in some cases, compile data on 

outcomes, such as employment or degree attainment. With the exception 

of the Texas Title I and Wagner-Peyser programs, the data systems are 

independent of each other, though in some instances, officials said data 

from the systems can be shared under established sharing agreements 

between agencies. For example, the VR program in Illinois has data 

sharing agreements in place with the Illinois agency that holds UI wage 

data and with the Social Security Administration to provide SSNs for data 

matching.

Officials in Selected 

States Anticipate 

Changes in How They 

Collect and Report 

Performance Data, 

Such As Integrating 

Data Systems, 

Though the Full 

Extent is Not Yet 

Known

Programs Vary in How 

they Currently Collect and 

Report Performance Data
Page 10 GAO-16-287 WIOA State Performance Data

Table 3: Summary Information on Case Management Data Systems in Illinois, New Hampshire, and Texas

State / core 

program State agency

Case management 

data system

Data system 

development

Examples of types 

of data elements

Program has 

access to state 

Unemployment 

Insurance (UI) 

wage data?

Current 

source of 

reported 

employment 

performance 

data

Illinois (IL)

Title I

programsa Illinois Department of 

Commerce and 

Economic 

Opportunity 

(Commerce)

Illinois Workforce 

Development 

System (IWDS)

StatedevelopedParticipant 

identification, eligibility 

determination, 

services received, 

employment status, 

program exit date and 

reason, wages

Yes UI wage data 

matching

Wagner-Peyser Illinois 

Department of 

Employment 

Security (IDES)

IllnoisJobLink.com 

(IJL)

VendorpurchasedParticipant 

identification, eligibility 

determination, 

services received, 

employment plans, 

employment status, 

education attainment, 

wages

Yes UI wage data 

matching

Adult Education 

and Family 

Literacy

Illinois 

Community 

College Board 

(ICCB)

Data and 

Information System 

- Illinois (DAISI)

Vendorpurchasedb Participant 

identification, 

employment status, 

placement and 

progress testing 

results, education 

attainment prior to 

program, program exit 

date and reason

Yes UI wage data 

matching

Vocational 

Rehabilitation

Illinois 

Department of 

Human Services 

(DHS)

WebCM StatedevelopedParticipant 

identification, disability 

data, services 

received, employment 

status, successful 

outcomes

Yes Individual 

outreach to 

participantsc

New 

Hampshire 

(NH)

Title I

programsa New Hampshire Department of 

Resources and 

Economic 

Development: 

Office of 

Workforce 

Opportunity 

(DRED-OWO)

Electronic Tracking 

Eligibility 

Assessment and 

Management 

Solution (ETEAMS)

VendorpurchasedParticipant 

identification 

information, services 

received, employment 

status

Yes UI wage data 

matching
Page 11 GAO-16-287 WIOA State Performance Data

State / core 

program State agency

Case management 

data system

Data system 

development

Examples of types 

of data elements

Program has 

access to state 

Unemployment 

Insurance (UI) 

wage data?

Current 

source of 

reported 

employment 

performance 

data

Wagner-Peyser New Hampshire 

Employment 

Security (NHES)

NH Works Job 

Match System

VendorpurchasedParticipant 

identification, 

employment plans, 

employment status, 

education attainment

Yes UI wage data 

matching

Adult Education 

and Family 

Literacy

New Hampshire 

Department of 

Education: 

Division of 

Career 

Technology and 

Adult Learning, 

Bureau of Adult 

Education

NH Adult Education 

Data System

StatedevelopedParticipant

identification 

information (no Social 

Security numbers), 

enrollment information 

(programs, classes, 

dates), educational 

levels and test scores, 

employment status, 

goal attainment

No Survey to 

participants

Vocational 

Rehabilitation

New Hampshire 

Department of 

Education: 

Division of 

Career 

Technology and 

Adult Learning, 

Bureau of 

Vocational 

Rehabilitation

AWARE - New 

Hampshire

VendorpurchasedParticipant 

identification 

information, eligibility 

determination, 

employment status, 

wage data

Yes Individual 

outreach to 

participants 

and UI wage 

data matching

Texas (TX)

Title I

programsa Texas Workforce Commission 

(TWC)

The Workforce 

Information System 

of Texas (TWIST)d

StatedevelopedParticipant 

identification, eligibility 

determination, 

services received, 

employment status, 

education attainment

Yes UI wage data 

matching

Wagner-Peyser TWC WorkInTexas.com 

(WIT)d Statedeveloped

Participant 

identification 

information, services 

received, employment 

status

Yes UI wage data 

matching

Adult Education 

and Family 

Literacy

TWC Texas Educating 

Adults Management 

System (TEAMS)

StatedevelopedParticipant 

identification, eligibility 

determination, 

services received, 

employment status, 

education attainment

Yes UI wage data 

matching
Page 12 GAO-16-287 WIOA State Performance Data

State / core 

program State agency

Case management 

data system

Data system 

development

Examples of types 

of data elements

Program has 

access to state 

Unemployment 

Insurance (UI) 

wage data?

Current 

source of 

reported 

employment 

performance 

data

Vocational 

Rehabilitation 

(general and 

blind programs)

Texas 

Department of 

Assistive and 

Rehabilitative 

Services (DARS)e

ReHabWorks StatedevelopedParticipant 

identification, eligibility 

determination, 

services received, 

employment status, 

education attainment, 

wages

Yes Individual 

outreach to 

participants

Source: GAO analysis of interviews with state program officials. | GAO-16-287

a Title I Programs include Title I Adult, Dislocated Worker, and Youth programs.

b Illinois Adult Education officials stated that while the program’s case management data system was 

purchased from a vendor, it is a custom-designed product and is not available for purchase on the 

open market.

c Illinois Vocational Rehabilitation officials stated that the program uses UI wage data to occasionally 

confirm continued employment, which is particularly useful when a participant has moved or program 

staff have lost contact with a participant.

d The TWIST and WIT data systems share data through regular, automated exchanges. In addition, 

they are the source of data used for federal performance reporting for Texas Title I and WagnerPeyser programs. The data from these systems are compiled in a separate system, called TWIST 

Web Reports, where UI wage data and other data are merged with participant information and then 

sent to the U.S. Department of Labor.

e The Vocational Rehabilitation program in Texas will be moving into TWC as of September 2016.

The performance reporting process varies based on program-specific 

circumstances, such as the source of reported participant outcome 

information and how automated the data collection and reporting 

processes are. Most programs in the three states we visited currently 

collect the employment outcome information reported to DOL and 

Education by matching participant data to state UI wage records.15

However, the VR program in all three of the states we visited currently 

collects employment information through individual outreach to program 

participants because program staff communicate regularly with 

participants and can readily obtain this information.16 In addition, the Adult 

Education program in New Hampshire collects employment outcome 

 15 Title I and Wagner-Peyser program officials in New Hampshire said they also collect 

employment and earnings information directly from participants for program management 

purposes so that they have the information sooner than through UI data matching.

16 The VR program in New Hampshire also collects some of its reported employment 

outcome data through UI wage data matching.
Page 13 GAO-16-287 WIOA State Performance Data

information by surveying participants.17 According to OCTAE, in the 2013-

14 performance year, the Adult Education programs in four additional 

states—Arizona, California, Hawaii, and New York—and the District of 

Columbia also collected participant employment information solely by 

surveying participants.18 As shown in case study 1 (see textbox), within 

the same state, programs may collect information differently. In New 

Hampshire, for example, Title I programs rely on data matching and the 

VR program relies on participant self-reporting and some data matching. 

Even when programs rely on similar sources of information, they 

sometimes use different mechanisms for obtaining and reporting 

participant information. For example, in New Hampshire Title I programs, 

a single official personally compiles participant outcome data and submits 

performance reports to DOL after the data are reviewed and approved by 

Title I management staff. According to the official, he obtains the outcome 

data from UI wage records through a standardized exchange with another 

state agency, New Hampshire Employment Security (see textbox). A data 

sharing agreement governs this process. Title I programs in Illinois 

similarly obtain participants’ employment information from UI wage 

records by exchanging data with the Illinois Department of Employment 

Security in accordance with a formal sharing agreement. In Texas, the 

reporting process is more automated for Title I programs, as participant 

data is automatically merged with UI wage data on a regular basis and 

then extracted into a federal data reporting system.

 17 New Hampshire Adult Education is the only program in the three states we visited that 

does not have access to state UI data, according to program officials.

18 American Samoa, Guam, Puerto Rico, and the Virgin Islands also relied solely on

participant surveys to collect employment information in program year 2013-14.
Page 14 GAO-16-287 WIOA State Performance Data

Case Study 1: Performance Reporting Processes Vary by Program in New 

Hampshire

Title I Programs (DOL-administered): Local office staff enter information about 

participants, including services received, into the program’s case management data 

system. To collect employment and earnings information for those individuals who 

participated in the reporting period, an official with the Title I programs sends participant 

Social Security numbers (SSNs) to the New Hampshire Employment Security agency to 

match with the state’s Unemployment Insurance (UI) wage records. According to program 

officials, a data sharing agreement and standardized exchange process facilitate the 

sharing. The official also sends participant SSNs to the federal Wage Record Interchange 

System to obtain information about those who may be working outside New Hampshire. 

The state ultimately submits the compiled outcome data to DOL, excluding participants’

personally identifiable information.

Vocational Rehabilitation Program (Education-administered): Local office staff enter 

information about participants, including eligibility determinations and services received, 

into the program’s case management data system. Program staff contact participants 

about every six weeks to determine whether they need any additional services or have 

obtained stable employment and thus can have their cases closed. Through this individual 

outreach, staff also collect outcome data that the state reports to Education at an 

individual participant level, including personally identifiable information. The program also 

has a data sharing agreement with the New Hampshire Employment Security agency to 

match participants to employment and earnings data; some of the matched data are also 

used for federal performance reporting.

Source: GAO analysis of interviews with New Hampshire program officials. | GAO-16-287

While officials in all three states we visited recognized they will need to 

collaborate more closely with core partners under WIOA, the extent to 

which they have already integrated their data systems, or plan to do so as 

a way to further this collaboration, varied. According to DOL and 

Education, WIOA encourages the development of integrated data 

systems across core programs to support integrated service delivery,

case management, tracking participation across programs, and reporting 

performance, among other things. Based on our analysis of literature on 

information technology (IT) structures and discussions with state officials, 

data system integration can take a variety of forms, ranging from 

approaches that focus on sharing data between existing systems to 

approaches that consolidate existing systems (see fig. 3).

States We Visited Are 

Considering or Have 

Begun Integrating 

Program Data Systems
Page 15 GAO-16-287 WIOA State Performance Data

Figure 3: Models of Potential Data System Integration for Performance Reporting
Page 16 GAO

-16-287 WIOA State Performance Data

Among the three states we visited, Texas is in the process of integrating 

core program data systems, and at the time of our visits, Illinois and New 

Hampshire were considering what approach to take related to integration. 

An overall vision for data system integration is laid out in the preamble to 

the proposed regulations and DOL officials said they have been engaging 

with states about issues related to integration. However, DOL officials 

said that they do not specify what model of data system integration states 

should adopt because states’ unique circumstances, such as their data 

system structures and the extent of existing integration, may make certain 

approaches more viable than others. For example, among the three 

states we visited, Illinois’ core programs are housed in four separate 

agencies, whereas in Texas, Title I, Wagner-Peyser, and Adult Education 

programs are all housed within a single agency and the Vocational 

Rehabilitation program will be moving into that agency as of September 

2016. These different structures and other factors, such as costs 

associated with integration, affect the states’ approaches to data system 

integration. DOL and OCTAE regional officials similarly observed that 

states they work with are taking a variety of approaches to data system 

integration, with some, such as Washington, Idaho, and Tennessee 

moving forward in different ways. For example, a DOL regional official 

said that Washington is exploring completely integrating its data systems 

and Idaho is examining linking or interfacing data from programs’

individual systems for performance reporting. An OCTAE area 

coordinator said that Tennessee has hired a contractor to develop its data 

system integration. Officials from two DOL regions also said that some 

states are waiting to move forward with data system integration until they 

have a more complete understanding of federal expectations from final 

regulations, and are instead focusing on other aspects of WIOA 

implementation in the meantime.

Texas is in the process of consolidating core programs into a single 

agency, the Texas Workforce Commission (TWC), and integrating 

program data systems at the performance reporting phase. The Adult 

Education program moved from the Texas Education Agency into TWC in 

September 2013, joining Title I and Wagner-Peyser programs. The 

Vocational Rehabilitation program will be joining the agency in September 

2016. While this consolidation has occurred independent of WIOA, Texas 

officials said that it has put the state ahead of the curve in terms of data 

system integration. Texas is integrating its core program data systems 

similar to the “back-end integration” model shown in figure 3. As shown in 

figure 4, according to Texas officials, the case management data systems 

used for the Title I and Wagner-Peyser programs send participant data to 

a repository where UI wage data from Texas and other states—via 

Texas
Page 17 GAO-16-287 WIOA State Performance Data

federal exchanges, such as WRIS—are also sent. The data in this 

repository are merged by participants’ SSNs and uploaded to a federal 

performance reporting system. This automated delivery and compiling of 

data from multiple programs and sources in the repository is the key 

feature that represents “back-end integration” in Texas. The Adult 

Education program has its own case management data system and 

conducts performance reporting independently. However, Texas officials 

said that the automated delivery both of Adult Education data into the 

common repository, and of performance reports from the repository to 

Education, are under development. Texas officials said they also plan to 

integrate VR’s data system and reporting into this common repository 

after the program transitions into TWC.
Page 18 GAO-16-287 WIOA State Performance Data

Figure 4: Current and Planned Integration of Core Program Data Systems and Performance Reporting at the Texas Workforce 

Commission (TWC)

a UI wage records include Texas UI wage records and other states’ UI wage data obtained from 

federal data exchanges (as depicted at the bottom of the figure). To obtain information on participants 

enrolled in post-secondary education, TWC staff extract participant SSNs and send them to the 

Texas Higher Education Coordinating Board, which matches them against enrollment data and then 

sends aggregate results back to TWC for reporting to the U.S. Department of Education.

Core programs in Illinois have not begun integrating data systems and 

state officials are currently considering what approach to take related to 

integration. Currently, core programs in Illinois each have their own 

independent data systems and state officials from all of the programs told 

us they were not yet clear what integration would mean for their data 

Illinois
Page 19 GAO-16-287 WIOA State Performance Data

systems. At the time of our visit, officials from some of the programs said 

that the Illinois governor’s office was involved in providing direction to the 

core programs about what data system integration will look like in Illinois. 

In the meantime, some officials said they were considering ways to 

increase data sharing between core programs. Depending on the ultimate 

direction Illinois takes, integration may mean substantial changes for core 

programs or more minor adjustments to how programs share data.

Officials from core programs in New Hampshire said they do not plan to 

develop major changes to integrate data systems because their existing, 

independent systems are functioning well and such changes would be too 

costly. Some officials discussed interfacing—automated data sharing 

between program data systems—as a possibility the state could explore, 

though they said that approach would also have associated costs.

State and DOL regional officials we spoke with said states do not yet 

know the full extent of changes to performance data collection and 

reporting that will be needed under WIOA because regulations and 

reporting templates have not been finalized. However, based on 

information in the law and the proposed regulations (jointly issued by DOL 

and Education in April 2015), as well as conversations between states, 

programs, and the federal agencies, program officials recognize that 

some changes will be needed to collect data on and calculate the new 

WIOA performance indicators. In addition, DOL and Education jointly 

released a proposed reporting template in July 2015 that provided 

information about proposed definitions for core indicators of performance, 

some of the specific data elements that need to be collected, and how to 

report performance on certain core indicators. DOL also released 

additional proposed details about data element definitions and 

specifications in September 2015.19 Programs in all three states we 

visited are engaged in conversations within and across core programs. 

For example, when we visited the states, Illinois officials were 

communicating about integration and were working with a contractor to 

facilitate discussions across core programs, and New Hampshire officials 

were beginning to coordinate the development of the state plan for 

implementation by convening stakeholder discussions.

 19 DOL and Education issued the proposed details and requested public comments on 

July 22, 2015. DOL released additional details on September 1, 2015. The public had a 

60-day period to submit comments on each.

New Hampshire

Though the Full Extent of 

Changes to Data 

Collection and Reporting 

is Not Yet Known, 

Expected Changes Vary 

by Core Program
Page 20 GAO-16-287 WIOA State Performance Data

The DOL-administered programs have experience with collecting and 

reporting data for employment and earnings indicators, and Title I and 

Wagner-Peyser officials in all three states we visited said they expected 

few or relatively minor changes to their performance reporting. The 

employment and earnings indicators under WIOA are similar to those 

reported under WIA for the DOL-administered programs, though median 

earnings (instead of mean earnings) are now calculated in the 2nd 

quarter after program exit, and employment is measured in the 2nd and 

4th quarters after program exit (instead of measuring employment in the 

1st quarter and then employment retention in the 2nd and 3rd quarters 

after exit). However, the measurable skill gains indicator is new to Title I

Adult and Dislocated Worker programs and these programs will have to 

develop ways of obtaining these data.

Because some WIOA reporting requirements are new to the Educationadministered programs, Adult Education and VR programs may face 

more substantial changes to collecting and reporting performance data 

than the DOL-administered programs. For example, the median earnings 

performance indicator is new for the Adult Education program. In addition, 

the VR program has generally reported employment and earnings 

outcomes at a single point in time for program participants—at the point a 

participant exits the program (i.e., once a participant has stable 

employment for 90 days)—and not thereafter (as the new indicators will 

require). To report on the new measures, these programs may have to 

develop new ways to collect information about employment and earnings 

and may need increased access to UI data. According to DOL, WIOA is 

intended to expand the use of state UI wage records, consistent with 

state law, for reporting employment and earnings outcomes. Of the 

programs in the states we visited, only the Adult Education program in 

New Hampshire does not currently have access to earnings information 

from state UI data, due to a state law prohibiting it from collecting SSNs, 

according to program officials. As a result, the Adult Education program in 

New Hampshire plans to obtain earnings information for federal reporting 

by adding a question about earnings to its participant survey. The Adult 

Education programs in Illinois and Texas currently use UI data matching 

to report on employment outcomes, and thus already have access to a 

source of earnings data.

State VR officials in the states we visited said they will have to track 

participants longer under WIOA due to the requirement to report on 

outcomes after program exit, and may need new ways of collecting 

information after a participant leaves the program. Contractors who 

administer VR data systems in New Hampshire and other states said that 
Page 21 GAO-16-287 WIOA State Performance Data

under WIOA, VR agencies will have to change how they think about 

storing data and long-term maintenance because the new common 

performance indicators will require a reporting method that relies on case 

management over a significant period of time. As a result, states will have 

to shift from reporting on the status of a participant when he or she leaves 

the program to reporting the participant’s progress in the second and 

fourth quarters after exiting the program. For example, VR officials in 

Illinois and Texas said that while they currently have access to UI wage 

data, they generally do not use them for federal performance reporting 

because program staff maintain contact with participants to collect 

employment status updates and other information until participants exit 

the program. However, they said they plan to begin using UI wage data 

matching under WIOA to report on employment and median earnings. VR 

officials in New Hampshire said the program already uses UI wage data 

matching to collect some of its reported employment outcome data, 

though it does not currently have access to UI wage records for 

participants who find employment outside New Hampshire.

The effectiveness in serving employers performance indicator will be new 

to all of the core programs, and how it will be measured has yet to be 

finalized. The statutory deadline for developing the indicator is July 2016. 

DOL and Education proposed several potential approaches to measuring 

this indicator in the proposed regulations. According to DOL, the agencies 

are analyzing comments received on these proposals. Some state and 

DOL regional officials said WIOA’s requirement to report on effectiveness 

in serving employers, and the emphasis on serving the business needs of 

employers, has generally increased awareness of employers as 

customers, in addition to program participants. For example, some state 

officials we spoke with said they expect they will need to develop ways to 

coordinate outreach to and interaction with employers across programs. 

New Hampshire Wagner-Peyser officials said they work with an 

interagency business team that has representatives from each of the core 

program agencies in order to eliminate duplication of effort and prevent 

employers from being burdened with repetitive visits. Illinois Title I officials 

similarly said programs will have to coordinate outreach to employers and 

added that under WIOA, programs will have to increase employer 

engagement to ensure that education and training is focused on employer 

demand (i.e., where jobs are available).

After DOL and Education issue final regulations and the full extent of 

changes is known, programs will still have to incorporate the performance 

reporting changes into their data systems. As shown in case study 2 (see 

textbox), those programs that have vendor-purchased systems may 
Page 22 GAO-16-287 WIOA State Performance Data

collaborate with or rely on their contractors to incorporate changes, while 

those programs that have systems developed in-house will be 

responsible for incorporating changes. Regardless of whether program 

officials or a vendor are responsible, the ability of programs to process 

changes before WIOA implementation deadlines may vary. For example, 

New Hampshire VR officials said their data system vendor expects to 

continue implementing changes through summer 2016. Texas VR officials 

said that the last time they implemented major changes to performance 

reporting, implementing the changes took about two years to complete 

from when the changes were first discussed.

Case Study 2: Incorporating Data System Changes Using Vendors Versus In-House 

Staff

New Hampshire Wagner-Peyser: Wagner-Peyser officials in New Hampshire expect 

their data system vendor to incorporate any needed changes resulting from WIOA in their 

case management system. According to officials, their vendor works with 30 state 

programs and will be implementing changes in an updated version of its case 

management data system product to reflect WIOA changes.

Texas Vocational Rehabilitation: According to officials, the Vocational Rehabilitation 

(VR) program in Texas is individually responsible for implementing data system changes. 

Information technology officials for the VR program said that to incorporate changes under 

WIOA they will receive a request from VR program officials, then develop, test, and 

incorporate changes into the program’s data system. The Texas officials said they had not 

yet received a change request from the VR program because officials are waiting for final 

WIOA requirements.

Source: GAO analysis of interviews with state program officials. | GAO-16-287

Federal officials are also considering ways to facilitate states’ WIOA 

implementation efforts. The preamble to the proposed regulations issued 

by DOL and Education in April 2015 states that the agencies intend to 

engage in a renegotiation of data sharing agreements with states 

(currently WRIS and WRIS2) to allow interstate wage matches for WIOA 

programs.20 DOL indicated it is considering the structure of the 

agreements moving forward, and will be working with Education and 

engaging the states in that development. In addition, the President’s fiscal 

year 2017 congressional budget justification for the Department of Health 

and Human Services (HHS) requests that select federal statistical and 

 20 WRIS allows the exchange of state wage record data for participants in workforce 

programs and WRIS2 allows the exchange of state wage record data for participants in 

related programs like VR. For more information, see GAO-15-764R.
Page 23 GAO-16-287 WIOA State Performance Data

evaluation units be granted access to data from the National Directory of 

New Hires (NDNH) for, among other things, performance measurement 

purposes.

21 The President’s Budget also proposes to provide state 

agencies with responsibilities for WIOA implementation the authority to 

match data with the NDNH for program administration purposes, including 

oversight and evaluation of these programs. Among other things, NDNH 

contains quarterly wage information on individual employees from state 

UI records and federal agencies. When we spoke with DOL and HHS 

officials about expanding access to NDNH, they told us that NDNH data 

could potentially be used for state WIOA performance reporting, though 

that would require that states be given legal access to NDNH data. 

However, when we spoke with HHS officials, they cautioned that the 

request is still in the early stages of consideration. Many additional details 

would have to be settled either in statute or in agreements between HHS 

and DOL, including how HHS would be reimbursed for use of the data 

and how the security of the data would be protected. For instance, 

according to the fiscal year 2017 proposal, HHS “would conduct robust 

privacy and security reviews before granting any state agency access to 

data.” When we spoke with them, HHS officials said they had not 

engaged in detailed discussions with DOL officials about these and other 

related issues.

 21 A similar request was also in the fiscal year 2016 congressional budget justification for 

HHS. According to DOL officials, access to NDNH data would primarily enable DOL to 

conduct national evaluations more efficiently; for instance, instead of having to negotiate 

data sharing agreements with every state to collect data for national evaluations, DOL 

would have access to national data in one source.
Page 24 GAO-16-287 WIOA State Performance Data

Program officials across all three states we visited reported challenges in 

the early stages of implementing the requirements of WIOA, in part 

because they are awaiting final regulations and seeking more guidance 

from DOL and Education. Many details about the reporting requirements 

will not be known until final regulations are issued.22 Under WIOA, they 

were due in January 2016, though DOL officials informed us they 

anticipate issuing them in June 2016. Generally, early implementation 

efforts in the states we visited are based on the proposed regulations, 

and some state officials are concerned that without knowing what the final 

regulations will entail, they may not have enough time to implement all 

changes before the July 2016 deadline to begin using the new common 

indicators of performance. To avoid investing resources in implementing 

aspects of performance reporting that might later change with the 

publication of final regulations, some states are focusing on other WIOA 

efforts, such as working with new program partners and discussing ways 

to share participant data efficiently, according to officials we spoke with in 

two states and one DOL regional office.

DOL and Education have provided some interim guidance in order to 

assist states as they await final regulations. As we noted previously, DOL 

and Education issued joint proposed regulations in April 2015, as well as 

 22 For example, in the preamble to the proposed regulations, DOL and Education 

discussed how to define the term “exit,” and asked for comments on the costs and 

benefits of taking a program-exit approach (exit occurs after participants leave the 

individual program), or a common exit approach (exit occurs after participants finish 

receiving services from all of the core programs). The requirements included in the final 

regulations may affect how states report performance on participants.

Limited Information 

About Reporting 

Requirements and 

the Difficulty of 

Integrating Data 

Systems Challenge 

Implementation in 

Selected States

Limited Information on 

Details of Reporting 

Requirements Slowed 

Implementation Planning
Page 25 GAO-16-287 WIOA State Performance Data

proposed performance reporting templates in the following months. In 

August 2015, DOL and Education also issued joint guidance on the vision 

for WIOA’s coordinated service delivery system and technical assistance 

resources available to states.

23 DOL’s ETA has issued other Training and 

Employment Guidance Letters (TEGLs) that cover various issues, such 

as planning information related to Title I Youth program funds and WIOA 

implementation activities.

24 OCTAE has also issued other guidance 

related to the Adult Education program, such as a program memorandum 

about the vision for the program within the workforce system, and 

guidance on the competition and award of program funds. In addition, 

DOL and Education officials told us they have worked together to provide 

webinars and have participated in joint conference calls with states. Some 

officials in the states we visited said that they have found this various 

guidance informative, particularly DOL’s TEGLs. However, receiving such 

guidance earlier would have been helpful, according to some program

officials in two of the three states we visited.

DOL has also responded to states’ questions informally, according to 

state officials, while Education officials have said that until regulations are 

finalized they can provide only limited information outside the formal 

regulatory comment process. Officials for DOL-administered programs in 

all three states we visited said they contact DOL regional officials for 

assistance, and several officials in New Hampshire reported that their 

DOL regional office has specifically helped them figure out answers to 

questions about WIOA. For example, New Hampshire’s Wagner-Peyser 

officials stated that although their DOL regional officials understandably 

lack information on final regulations, they have been helpful in providing 

suggestions on how to plan for WIOA and encouraging officials not to wait 

until final regulations to move forward with implementation. Similarly, a 

DOL regional official said he meets with states every two weeks to 

discuss issues on the ground, such as training and WIOA definitions 

related to performance reporting. In contrast, Education officials from 

RSA and OCTAE have told states that they cannot answer questions that 

relate to ongoing rulemaking. For example, according to Education 

 23 This guidance was issued by DOL as Training and Employment Guidance Letter No. 

04-15 and by Education’s OCTAE and RSA as Program Memorandum OCTAE 15-3 and 

Technical Assistance Circular RSA-TAC-15-01, respectively.

24 DOL provides guidance to states in the form of Training and Employment Guidance 

Letters and Notices.
Page 26 GAO-16-287 WIOA State Performance Data

officials, they have responded to questions about performance indicators 

by referring states to the relevant provisions in WIOA and the proposed 

regulations.

While WIOA encourages the integration of data systems, state capacity to 

pursue integration varies. In the states we visited, Texas is currently 

integrating its data systems, but officials in New Hampshire and Illinois 

said that the cost of data system integration will be a major challenge. For 

example, officials in every core program in New Hampshire reported that 

developing a new, integrated data system is cost-prohibitive. Similarly, a 

DOL regional official said that the majority of states in his region face 

challenges with data integration that include the expense of developing 

an integrated system and determining which systems will need to be 

redesigned. While states have some flexibility in how they can use their 

WIOA funding, DOL and Education officials told us that there are federal 

and state restrictions on the amount available for data integration and IT 

system upgrades.25

To help fund data system integration, DOL and Education have requested 

funding to provide assistance to states. In the President’s fiscal year 2016 

congressional budget justification for ETA, the agency asked for $37 

million under the Workforce Data Quality Initiative, of which $30 million 

would be to “help states build integrated or bridged data systems to 

facilitate WIOA implementation... [and] support building state-based wage 

data matching infrastructure to enable and/or streamline WIOA 

performance reporting.”26 Similarly, as part of its fiscal year 2016 budget 

request for the Adult Education program, Education asked for $1 million 

 25 According to DOL, WIOA transition authority and language in the ETA appropriation 

enabled certain funds to support a range of transitional activities, including supporting the 

transition of reporting and IT systems. For example, section 503(g) of WIOA permits the 

use of certain fiscal year 2014 funds for transitional purposes, and the Department of 

Labor Appropriations Act, 2015, provided flexibility for DOL to issue an allotment of 

Dislocated Worker National Reserve Funds for WIOA transition activities.

26 The Workforce Data Quality Initiative is a grant program administered by ETA, and is 

intended, in part, to help state grantees (1) develop or improve state workforce 

longitudinal data systems, (2) enable workforce data to be matched with education data, 

(3) improve the quality and breadth of data in workforce longitudinal data systems, (4) use 

longitudinal data to evaluate the performance of education and job training programs, and 

(5) provide user-friendly information to consumers to help them select education and 

training programs. For more information, see GAO-15-27.

States GAO Visited 

Reported that Resource 

Constraints and Data 

Security Issues Present 

Challenges for Integrating 

and Sharing Data
Page 27 GAO-16-287 WIOA State Performance Data

to provide technical assistance to states in the collection of new data 

elements and integration of data systems. Officials at both agencies told 

us that the funding requests were not intended to cover all data 

integration costs, but instead to provide some assistance to states. The 

Consolidated Appropriations Act, 2016, provided $6 million for the 

Workforce Data Quality Initiative and did not provide the full amount of 

funding Education requested to provide technical assistance to states.27

In the President’s Budget for fiscal year 2017, both agencies again 

requested funding to support states’ data integration efforts. Under the 

Workforce Data Quality Initiative, ETA asked for $40 million, of which $33 

million would be to help states build integrated data systems to facilitate 

WIOA implementation. Under the Adult Education program, Education 

asked for $6 million to support the collection of new data elements and 

the integration of data systems.

Aside from cost, state and federal officials also identified other capacity 

concerns in this area, including limited staff expertise and antiquated IT 

systems. According to DOL officials, state efforts to integrate data 

systems may be challenged by, among other things, constraints in their 

ability to retain qualified IT staff due to state salaries that are low 

compared to those in the private sector. One DOL regional official said 

that due to budget cuts and layoffs in one of her states, the remaining 

staff lacks knowledgeable data programmers. Some program officials in 

New Hampshire expressed similar concerns about limited expertise to 

develop data system integration. For example, a New Hampshire 

Vocational Rehabilitation official reported that the state’s IT department 

has reduced its labor force and has limited staff capacity to support data 

system integration. According to DOL officials, many states have 

significantly antiquated and inflexible IT systems, making it challenging to 

support data system integration. Officials in two DOL regional offices 

similarly reported that rather than upgrading data systems, states have 

added patches over the years to respond to changes to reporting 

requirements, resulting in antiquated systems that make integration 

difficult.

As part of data system integration, WIOA encourages states to share and 

match data across programs, but officials reported that efforts to do so 

 27 The $6 million in the Act is available for the period July 1, 2016 through June 30, 2017, 

though DOL’s requested $37 million was for the period April 1, 2016 through June 30, 

2017, according to its congressional budget justification.
Page 28 GAO-16-287 WIOA State Performance Data

may be challenged by security concerns and undeveloped relationships. 

Officials in two of the three states we visited and a DOL regional official 

said that concerns over data security may impede states’ efforts to obtain 

participant information from core program partners. For example, a New 

Hampshire official said she would have concerns about sharing data with 

other agencies because she does not manage or oversee the data 

security standards they follow. These security concerns may be the 

result, in part, of undeveloped relationships between partners. According 

to a study by the Center for Regional Economic Competitiveness (CREC), 

one of the challenges to data sharing is a lack of trust between partners, 

particularly related to the intent and ability of the entity requesting data to 

use the data appropriately and protect it from any breach of 

confidentiality. The study identifies establishing mechanisms to build trust 

between entities interested in obtaining data from each other as one 

successful strategy for responding to this challenge and improving data 

sharing conditions.28

DOL and Education intend that WIOA’s common indicators of 

performance will, among other things, enable consistent outcome 

comparisons across states. WIOA requires the use of quarterly wage 

records, consistent with state laws, and the preamble to the proposed 

regulations emphasizes data-matching by participant SSN as a way of 

encouraging timely and accurate data for employment and earnings 

measures across the different programs and states. However, under 

federal law, state and local government agencies generally cannot require 

individuals to provide their SSNs as a condition of receiving program 

 28 Center for Regional Economic Competiveness, Balancing Confidentiality and Access: 

Sharing Employment and Wage Data for Policy Analysis and Research (Arlington, VA: 

May 2015). CREC is an independent, non-profit organization that conducts research for 

and provides technical assistance to various policymakers at all levels of government in 

the areas of workforce and economic development. CREC manages the Labor Market 

Information (LMI) Institute, which is a membership organization comprised of state LMI 

entities and independent LMI professionals. In Balancing Confidentiality and Access, 

CREC collected information about state laws and data sharing agreements from states 

(33 states sent information of some kind), and also held a workshop and conducted 

interviews to learn about data sharing issues in states. To find participants for both the indepth interviews and the workshop, officials reached out across the LMI membership 

organization. Interviewees included LMI agencies, independent research organizations, 

university research centers, community colleges, national associations that deal with 

these issues, state agencies that deal with economic development, and legal counsels 

from LMI agencies or states, among others.

Limitations on Available 

Data May Challenge the 

Quality of Performance 

Information
Page 29 GAO-16-287 WIOA State Performance Data

services. In addition, not all programs collect SSNs from some, or all, 

participants, thus making it difficult to match participant data. For 

example, according to OCTAE officials, Adult Education programs in 

some states have reported to them that they have difficulty collecting 

SSNs due to state privacy laws. OCTAE officials said that in the absence 

of SSNs, states can use other methods to collect data for performance 

reporting purposes, such as participant surveys. As shown in case study 

3 (see textbox), other strategies for mitigating data gaps include the 

development of alternative methods of data matching, instead of using 

SSNs.

Case Study 3: Matching Participant Data Without SSNs

In November 2014, we reported on challenges certain states experienced matching 

education and workforce program data as part of their efforts to develop statewide 

longitudinal data systems, which, among other things, allow states to follow individuals 

through their education and into the workforce. Officials in three of the five states visited 

as part of that review said state law or agency policy prohibit collecting a SSN in certain 

education programs. As a result, to match education and workforce data without a SSN, 

state officials reported they are developing algorithms to match individual records using 

other identifiers, such as an individual’s first name, last name, and date of birth.

Wagner-Peyser officials in New Hampshire told us that they are able to match participants’

information based on other personally identifiable information (PII), such as name and 

date of birth, with UI data if a participant does not provide a SSN. Similarly, according to 

officials in Texas, the Adult Education program is able to match three of four elements 

(first name, last name, date of birth, or SSN) to obtain select education outcomes from the 

Texas Education Agency. However, Texas officials reported to us that relying on names 

for data matching may not be ideal, as names may change throughout an individual’s 

lifetime. DOL officials told us that states are making advances in obtaining participant 

information through secure portals for matching in which users are not able to see 

participants’ PII. In addition, DOL officials said they are aware of work groups that are 

developing ways to use advanced technology to do data matching without SSNs.

Source: GAO analysis of interviews with state and federal program officials and GAO, Education and Workforce Data: Challenges in 

Matching Student and Worker Information Raise Concerns about Longitudinal Data Systems, GAO-15-27 (Washington, D.C.: 

November 19, 2014). | GAO-16-287

Even when programs have participant SSNs, they may face other 

constraints in their ability to match with UI data. According to the CREC 

study, the decision to share or withhold employment and wage data is 

largely based on how a state interprets UI data confidentiality statutes 

and regulations. The study found that the states that have been most 

successful in promoting data sharing are those with legislation that 
Page 30 GAO-16-287 WIOA State Performance Data

provides greater detail about both to whom and for what purposes 

confidential data may be disclosed.29

Data gaps may continue to affect the quality of performance data reported 

in the Adult Education program. For example, state programs that do not 

collect SSNs, such as New Hampshire, may continue to utilize surveys or 

individual participant follow-up as a means to collect information on 

earnings. However, an Adult Education official in New Hampshire said 

that adding questions to participant outcome surveys to collect 

information for the WIOA median earnings performance indicator may 

discourage respondents from filling out the surveys and drop the 

response rate below OCTAE’s minimum acceptable level.

30 Even when a 

state Adult Education program uses UI wage data matching, some 

participants do not provide SSNs—sometimes in large numbers. For 

example, Adult Education officials in Texas said their rate of matching 

participants to wage data using SSNs was about 55 percent. According to 

the statistical formulas OCTAE uses to calculate weighted performance 

outcomes for state Adult Education programs, participants whose 

employment outcome information is missing (i.e., whose data cannot be 

matched with UI wage records or who do not respond to surveys) are 

assumed to obtain employment at the same rates as those participants 

with data available. OCTAE officials said they have not assessed whether 

differences exist between populations that respond to surveys or who

submit SSNs and those who do not respond or do not submit SSNs. 

Officials reported that such an analysis of nonresponse bias would not be 

technically feasible within each state before submitting performance data, 

 29 CREC, Balancing Confidentiality and Access.

30 According to OCTAE officials, under WIA, a minimum response rate of 50 percent was 

required for reporting performance on all Adult Education participants via survey, and if a 

state surveyed a sample of participants, the minimum acceptable response rate was 70 

percent. Under WIA, if a state conducted a survey and fell below the minimum acceptable 

response rate, then OCTAE did not consider the survey results to be valid and the state 

failed the performance indicator being surveyed. According to Education officials, although 

WIA did not authorize Education to impose sanctions on states that failed agreed-upon 

performance levels, if a state did not meet the required response rate for an indicator, 

Education counted it as a zero in considering the state’s performance for incentive grants. 

In addition, Education officials stated they required a state that failed to meet the minimum 

required response rate for an indicator to develop and submit a Data Quality Improvement 

Plan, which officials monitored through remote and on-site monitoring. Section 116(f) of 

WIOA authorizes sanctions for a state’s failure to meet adjusted levels of performance.
Page 31 GAO-16-287 WIOA State Performance Data

and similarly would not be feasible for OCTAE staff since state data are 

reported in the aggregate.31

DOL regional officials also raised concerns about the accuracy of 

performance data reported by states. DOL regional officials annually 

review a sample of case files from selected states to assess the validity of 

data states submit for performance reporting, and provide feedback to 

states based on their findings. According to DOL regional officials, these 

regularly recurring data validation reviews are conducted by the regional 

officials after states have submitted their performance data. Regional 

officials review the data element validation results, including the error 

rates and provide technical assistance to states as appropriate, according 

to DOL officials. Officials in two of the three DOL regional offices we 

spoke with said they have recently identified higher-than-desired error 

rates in performance data reported to the federal government in their 

routine reviews. For example, one regional official found that a state failed 

to update its data system and as a result, reported inaccurate information 

about the level of education completed by program participants. DOL 

officials told us that due to resource limitations, they have not performed 

any analysis to determine how such error rates may or may not affect the 

overall accuracy of outcome data. According to DOL officials, although 

the data validation reviews conducted by regional officials are not tied to 

sanctions, states are expected to use the findings of the reviews to 

improve the quality of data they submit for performance reporting in the 

future.32 OCTAE also conducts risk-based monitoring of state Adult 

Education programs, which covers data quality issues. One recent 

monitoring report found that a state program’s data system did not include 

required automated checks for errors and invalid data.

 31 Nonresponse bias occurs when those who do not respond to a survey would have 

answered differently than those who do respond. Thus, the results of the survey may not 

accurately depict the target population. According to OCTAE officials, requiring each state 

to conduct nonresponse bias analysis would place an unreasonable burden on states 

because conducting such analyses requires resources, time, and technical knowledge 

which may not be currently available.

32 In addition, according to DOL, prior to WIOA, data validation outcomes were a criterion

in determining eligibility for incentive awards, which do not exist under WIOA.
Page 32 GAO-16-287 WIOA State Performance Data

New WIOA reporting requirements will increase the responsibilities for 

Eligible Training Providers (ETPs) to track employment outcomes for 

training participants, including participants who are not enrolled in WIOA 

programs.33 State officials in all three states we visited said that these 

additional performance reporting requirements may discourage some 

ETPs from participating as WIOA training providers because the ETPs 

believe reporting on non-DOL-funded participants will be burdensome. 

Texas officials said that they have been working with ETPs in their state 

to find ways to reduce the burden while still complying with WIOA. In prior 

work, we identified similar concerns during the transition to WIA.34

However, according to DOL, to balance these concerns while still 

gathering enough information for participants and others to make 

informed choices about which training providers to use, states were 

ultimately able to obtain a waiver from certain reporting requirements for 

ETPs under WIA. Forty-one states obtained the waiver, according to 

DOL. DOL officials told us that they are aware of the challenges that 

states have expressed related to understanding where the burden lies for 

ETP performance reporting in both data collection and reporting. For 

example, DOL officials told us that not all ETPs have access to UI wage 

data. DOL officials said they solicited feedback on the proposed 

regulations and performance reporting templates in order to work through 

these issues, and that these details will be addressed in the final 

regulations and reporting templates, as well as in future joint guidance 

from DOL and Education on data access.

State Vocational Rehabilitation officials in two of the three states we 

visited noted that identifying and tracking participants receiving preemployment transition services, as well as reporting on new WIOA 

performance indicators for these participants, may be difficult. WIOA 

emphasizes pre-employment transition services, which assist students 

with disabilities transitioning from secondary school into postsecondary 

 33 Certain WIOA Title I program participants can receive training from ETPs, such as 

community and technical colleges. States maintain lists of ETPs to assist participants in 

choosing employment and training activities. Under WIA, ETPs reported certain outcomes, 

such as employment and earnings, for WIA program participants.

34 GAO, Workforce Investment Act: Better Guidance Needed to Address Concerns Over 

New Requirements, GAO-02-72 (Washington, D.C.: October 2001).

State Officials Identified 

Reporting Changes that 

May Be Especially 

Challenging, Such As 

Collecting and Measuring 

Outcome Data for Certain 

Populations
Page 33 GAO-16-287 WIOA State Performance Data

education or employment.35 WIOA states that these services are to be 

provided to students with disabilities who are eligible or “potentially 

eligible” for services, but New Hampshire and Texas officials said they did 

not know how to identify, serve, and track “potentially eligible”

participants. According to Education, each VR program grantee received 

terms attached to their fiscal year 2016 grant award describing the 

requirements for the provision of pre-employment transition services to all 

students with disabilities who are eligible or potentially eligible for VR 

services. In addition, the agency noted that RSA plans to provide more 

extensive guidance related to this issue in the future.

DOL and Education officials are largely aware of and, in some cases, 

actively working to help address the challenges the states we visited 

raised related to their ability to timely implement WIOA’s vision for 

performance reporting. In this process, the federal agencies are balancing 

the benefits of issuing guidance as early as possible with the importance 

of considering a broad array of stakeholder input via the ongoing 

rulemaking process. In some cases, the departments have tried to 

assuage states’ concerns through the guidance and ongoing dialogue 

discussed earlier. However, DOL and Education officials also 

acknowledge they likely cannot more fully mitigate states’ concerns until 

they issue final WIOA regulations and subsequently begin to develop 

more detailed implementation guidance. Among other things, the 

departments noted that in several areas, the proposed regulations sought 

suggestions and other input on key aspects of WIOA rather than spelling 

out explicit proposed rules (e.g., different ways to define program exit or 

ideas on how to measure the effectiveness in serving employers 

indicator), an approach that likely contributes to some states’ hesitancy to 

plan specific implementation steps or commit resources to them. 

According to DOL officials, the departments expect to issue final 

regulations in June 2016, which is after the date called for in WIOA. They 

attribute this delay to the scope and complexity of the new law, the 

 35 WIOA requires states to provide pre-employment transition services to all eligible or 

potentially eligible students with disabilities. These services include job exploration 

counseling; work-based learning experiences; counseling on opportunities for enrollment 

in comprehensive transition or postsecondary educational programs; workplace readiness 

training to develop social skills and independent living; and instruction in self-advocacy. 

WIOA requires states to reserve no less than 15 percent of their VR funding for the 

provision of pre-employment transition services, excluding the administrative costs of 

providing the services.

In Helping to Address 

Challenges States Are 

Facing, Federal Agencies 

are Balancing Benefits of 

Providing Timely Guidance 

and Considering 

Stakeholder Input
Page 34 GAO-16-287 WIOA State Performance Data

volume of comments received on the proposed regulations, and the 

importance they are placing on a thoughtful and deliberative treatment of 

the many stakeholders’ perspectives and input.

Officials in all three states we visited reported that they were not aware of 

any outside intrusions into the electronic data systems for core WIOA 

programs during the years they worked in the programs.36 However, 

officials in Illinois and Texas reported other types of occasional data or 

security breaches that resulted in inappropriate exposure of PII for small 

numbers of people in limited circumstances. For example, Texas officials 

described a few instances of paper records with PII stolen from vehicles, 

a few times when unencrypted data were transferred electronically from 

local offices to the state, and an instance in which an employee included 

PII in internal emails. Officials said an electronic flag in the Texas email 

system currently identifies SSN-like numbers that appear in emails from 

program employees before they are sent so employees can remove any 

SSNs. An Illinois official reported that a staff member once placed paper 

PII in a non-secure trash container. Officials in another Illinois program 

 36 The term “data breach” generally refers to the unauthorized or unintentional exposure, 

disclosure, or loss of sensitive information, including PII. PII refers to any information 

about an individual maintained by an agency, including (1) any information that can be 

used to distinguish or trace an individual’s identity, such as name, SSN, date and place of 

birth, mother’s maiden name, or biometric records; and (2) any other information that is 

linked or linkable to an individual, such as medical, educational, financial, and employment 

information. GAO-14-34.

Three States GAO 

Visited Reported No 

Intrusions into their 

Data Systems and 

that they Take Steps 

to Limit and 

Safeguard Personal 

Information Collected

Three States GAO Visited 

Reported No Intrusions 

into their Data Systems, 

Though Some Officials 

Cited Other Limited 

Security Breaches
Page 35 GAO-16-287 WIOA State Performance Data

said they found that some of the entities with which they shared data did 

not have certain security practices in place; the entities reported this 

information in response to a questionnaire regarding data security 

practices administered by the program as part of the data sharing 

application process. For example, some of the entities were faxing 

paperwork with PII. Officials said they have used the answers to this 

questionnaire to help tighten data security with certain sharing partners, 

including mandating the use of Secure File Transfer Protocol for data 

sharing.37

Officials in all three states said they had protocols for reporting a breach 

of PII, often reporting the incident to a security officer or a program 

supervisor. For example, in the Illinois Vocational Rehabilitation program, 

officials told us that staff are to report data breaches to the program 

director and to the agency’s Chief Information Officer or to the secretary 

of the agency, and that such breaches must be reported to the governor 

and the state legislature within 24 hours. Illinois Adult Education officials 

also said they have procedures to investigate incidents and inform 

affected program participants. According to officials in New Hampshire’s 

Wagner-Peyser program, the program is required by the state to have a 

continuity of operations plan in place, which includes responding to data 

breaches. The response plan is coordinated by an official in the agency 

commissioner’s office who is responsible for overseeing data security.

One of the ways that some programs reduce risks associated with the 

unauthorized disclosure of PII is to limit what is collected from 

participants, including involving participants in consenting to the collection 

of information, which is consistent with the Fair Information Practice 

Principles. According to the Privacy Act of 1974, government agencies 

generally cannot deny services to participants because of a refusal to 

provide SSNs.38 In 11 of the 12 programs across the three states, officials 

told us they allow applicants to opt out of providing their SSNs and still 

 37 Secure File Transfer Protocol uses encryption to securely transfer files between two 

computers.

38 5 U.S.C. § 552a note. For DOL’s guidance, see DOL, Training and Employment 

Guidance Letter No. 5-08, Policy for Collection and Use of Workforce System Participants’ 

Social Security Numbers (Washington, D.C.: November 13, 2008).

Program Officials in the 

Three States Reported 

They Generally Limit the 

Collection and Use of 

Personally Identifiable 

Information
Page 36 GAO-16-287 WIOA State Performance Data

receive services if found otherwise eligible.39 One New Hampshire 

program only uses the last 4 digits of a participant’s SSN in its data 

systems and prohibits the transmission of the entire SSN. In addition, 

officials in at least one program in each of the three states also specified 

that they allow applicants to opt out of providing other types of PII, such 

as date of birth. While, as previously mentioned, many Adult Education 

program participants in the states we visited do not provide SSNs, Title I 

and Wagner-Peyser officials in New Hampshire and Texas told us that 

relatively few participants in their programs opt out of supplying their 

SSNs or other PII.

One New Hampshire program reduces the possibility of unauthorized PII 

disclosures by asking for personal identification to establish identity, but 

not storing the PII in any files. This practice is consistent with the Fair 

Information Practice Principle of minimizing data collection to only directly 

relevant information. Officials in the New Hampshire program said that 

staff ask applicants to provide identity documents (e.g., driver’s license, 

military separation paperwork, or Social Security card), and then staff 

conduct a visual verification of the documents without scanning them into 

their electronic data system or making copies for a paper record file. An 

official from one DOL region suggested that states could consider more 

frequently using visual verification of documents with PII without making 

copies. As a result, state programs would not store that PII.

Officials in all three states we visited also explained that they inform 

applicants for services about how the programs will use their PII, typically 

by asking applicants to read and sign a form indicating why their PII is 

being collected and how it will be used. This is consistent with the Fair 

Information Practice Principles. The forms explain the types of allowable 

uses of PII, among other things. For example, an information disclosure 

form for the VR program in New Hampshire informs participants that 

personal information is confidential and will not be released without their 

written permission, except when information must be released as required 

 39 In the remaining program—Illinois VR—officials told us they require a participant to 

provide a SSN to receive services, at least at the point of eligibility determination. When 

we mentioned to RSA officials that this may be occurring, they indicated that such a 

practice would not be permitted under the law. We subsequently referred this specific 

Illinois VR practice of requiring SSNs to the attention of RSA to look into further as they 

determine necessary. For this analysis, we considered the three Title I programs in each 

state (i.e., Adult, Youth, and Dislocated Worker) as a single program because the officials 

we interviewed during our visits administered Title I programs generally.
Page 37 GAO-16-287 WIOA State Performance Data

by federal authorities or in other circumstances specified on the form. The 

disclosure form states that information can be shared, with consent, with 

other related state programs with which the participant is involved and 

with entities involved in audit, evaluation, or research directly connected 

with administration of the program.

In prior work, we identified actions in the areas of security management 

and access controls, among others, as important for keeping data 

secure;40 these are also consistent with the Fair Information Practice 

Principle of protecting data through safeguards against risks.41 Officials in 

the three states we visited reported using various practices in these 

areas. For example, in terms of security management, state officials 

reported various activities related to the design and operation of their data 

systems, including:

• state data security protocols (together with federal guidance) that 

establish practices for handling both electronic and paper PII;

• data security training that staff must attend periodically, as well as 

staff being required to sign a confidentiality (also called nondisclosure) 

agreement; and

• data sharing agreements with another state agency that must have 

proper PII protection procedures included, with programs owning the 

PII reviewing current or proposed data sharing agreements, and 

entities requesting data sharing required to provide evidence of 

acceptable data security procedures.

 40 GAO, Federal Information System Controls Audit Manual (FISCAM), GAO-09-232G 

(Washington, D.C.: February 2, 2009). Various guidelines and standards exist for 

protecting data security, including Erika McCallister, Tim Grance, and Karen Scarfone, 

Guide to Protecting the Confidentiality of Personally Identifiable Information (PII): 

Recommendations of the National Institute of Standards and Technology, U.S. 

Department of Commerce, NIST Special Publication 800-122 (Gaithersburg, MD: April 

2010).

41 The Fair Information Practice Principle of protecting data through safeguards against 

risks includes practices such as protecting against unauthorized access, accountability 

through training, and limiting sharing of data for appropriate and specified purposes. The 

Fair Information Practice Principles are cited in The White House, National Strategy for 

Trusted Identities in Cyberspace.

Officials in the Three 

States Reported Using 

Various Practices to 

Safeguard Information 

Collected
Page 38 GAO-16-287 WIOA State Performance Data

Related to physical and data system access controls, state officials said 

that among other practices, they:

• use secured entry for buildings containing PII;

• keep data on a secure network and access to the network has levels 

of set privileges based on a staff member’s role; with staff computers 

password protected and locked after a certain time period of inactivity; 

and

• require staff to use encryption software to safeguard data whenever 

sending sensitive information via email or when transferring data.

In addition, the core programs in Texas have a periodic “penetration test”

to try to identify possible vulnerabilities that outsiders could use to access 

the data. The central state entity for information resources conducts these 

tests individually for each state agency; staff from that entity attempt to 

hack into the data system as if they were outsiders. The Texas core 

programs also perform self-assessments of data security. New 

Hampshire’s central entity for information resources also conducts scans 

on data servers for vulnerabilities.

We provided copies of this draft report to the Department of Education 

and the Department of Labor for review and comment. Both departments 

provided technical comments, which we have incorporated as 

appropriate. The Department of Labor provided a transmittal letter with its 

comments, which is reproduced in appendix I. The letter highlights DOL’s 

work with Education to create a unified vision of WIOA performance 

accountability through guidance, technical assistance, and rulemaking. 

The letter also cites DOL’s goal in the coming year of providing guidance 

on data validation, as well as other performance accountability topics 

such as wage record sharing and negotiations of performance targets. 

We also provided copies of this draft report to officials from the state 

programs we visited for their review, and incorporated their technical 

comments as appropriate.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Labor, the Secretary of Education, and other 

interested parties. In addition, the report is available at no charge on the 

GAO website at http://www.gao.gov.

Agency Comments
Page 39 GAO-16-287 WIOA State Performance Data

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

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

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

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

are listed in appendix II.

Andrew Sherrill

Director, Education, Workforce, and Income Security Issues
Appendix I: Comments from the U.S. 

Department of Labor

Page 40 GAO-16-287 WIOA State Performance Data

Appendix I: Comments from the U.S. 

Department of Labor
Appendix I: Comments from the U.S. 

Department of Labor

Page 41 GAO-16-287 WIOA State Performance Data
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 42 GAO-16-287 WIOA State Performance Data

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

In addition to the contact named above, Bill MacBlane (Assistant 

Director), Michael Kniss (Analyst-in-Charge), Kelsey Kreider, Ada 

Nwadugbo, and Paul Wright, along with James Bennett, Marisol Cruz, 

John de Ferrari, Alex Galuten, Danielle Giese, Farrah Graham, Amy 

Moran Lowe, Sheila McCoy, Walter Vance, and Charlie Willson made 

significant contributions to this report.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 43 GAO-16-287 WIOA State Performance Data

Workforce Innovation and Opportunity Act: Performance Reporting and 

Related Challenges. GAO-15-764R. Washington, D.C.: September 23, 

2015.

Education and Workforce Data: Challenges in Matching Student and 

Worker Information Raise Concerns about Longitudinal Data Systems. 

GAO-15-27. Washington, D.C.: November 19, 2014.

Workforce Investment Act: Strategies Needed to Improve Certain Training 

Outcome Data. GAO-14-137. Washington, D.C.: January 31, 2014.

Information Security: Agency Responses to Breaches of Personally 

Identifiable Information Need to Be More Consistent. GAO-14-34. 

Washington, D.C.: December 9, 2013.

Workforce Investment Act: DOL Should Do More to Improve the Quality 

of Participant Data. GAO-14-4. Washington, D.C.: December 2, 2013.

Unemployment Insurance Information Technology: States Face 

Challenges in Modernization Efforts. GAO-13-859T. Washington, D.C.: 

September 11, 2013.

Information Technology: Department of Labor Could Further Facilitate 

Modernization of States’ Unemployment Insurance Systems. 

GAO-12-957. Washington, D.C.: September 26, 2012.

Federal Information System Controls Audit Manual (FISCAM).

GAO-09-232G. Washington, D.C.: February 2, 2009.

Workforce Investment Act: Additional Actions Would Further Improve the 

Workforce System. GAO-07-105IT. Washington, D.C.: June 28, 2007.

Workforce Investment Act: Employers Found One-Stop Centers Useful in 

Hiring Low-Skilled Workers; Performance Information Could Help Gauge 

Employer Involvement. GAO-07-167. Washington, D.C.: December 22, 

2006.

Workforce Investment Act: Labor and States Have Taken Actions to 

Improve Data Quality, but Additional Steps Are Needed. GAO-06-82. 

Washington, D.C.: November 14, 2005.

Related GAO Products
Related GAO Products

Page 44 GAO-16-287 WIOA State Performance Data

Workforce Investment Act: Substantial Funds Are Used for Training, but 

Little Is Known Nationally about Training Outcomes. GAO-05-650. 

Washington, D.C.: June 29, 2005.

Workforce Investment Act: Labor Should Consider Alternative 

Approaches to Implement New Performance and Reporting 

Requirements. GAO-05-539. Washington, D.C.: May 27, 2005.

Workforce Investment Act: States and Local Areas Have Developed 

Strategies to Assess Performance, but Labor Could Do More to Help. 

GAO-04-657. Washington, D.C.: June 1, 2004.

Workforce Investment Act: Labor Actions Can Help States Improve 

Quality of Performance Outcome Data and Delivery of Youth Services. 

GAO-04-308. Washington, D.C.: February 23, 2004.

Workforce Investment Act: Improvements Needed in Performance 

Measures to Provide a More Accurate Picture of WIA’s Effectiveness.

GAO-02-275. Washington, D.C.: February 1, 2002.

Workforce Investment Act: Better Guidance Needed to Address Concerns 

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

2001.

(131362)
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (http://www.gao.gov). Each weekday 

afternoon, GAO posts on its website newly released reports, testimony, 

and correspondence. To have GAO e-mail you a list of newly posted 

products, go to http://www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube.

Subscribe to our RSS Feeds or E-mail Updates. 

Listen to our Podcasts and read The Watchblog.

Visit GAO on the web at www.gao.gov.

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Please Print on Recycled Paper.