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). For the core programs, WIOA establishes six performance indicators on which states must report, with some exceptions (see table 2). 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. 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). Prior to WIOA, coordination among DOL- administered 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 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). 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. 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. 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 specification, data minimization, use limitation, data quality and integrity, security, and accountability and auditing. 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). 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. 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. 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. In addition, the Adult Education program in New Hampshire collects employment outcome information by surveying participants. 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. 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. 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. 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). 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.