The Workforce Investment Act of 1998 requires states and localities to bring together about 17 federally funded employment and training services into a single system—the one-stop system. Funded through four federal agencies, these programs, also known as the mandatory partner programs (or more simply, mandatory partners), are to provide services through a statewide network of one-stop career centers. (See table 1.) Three of these 17 programs, which were created and funded by Title I of WIA to provide services to adults, dislocated workers, and youth, replace those previously funded under the Job Training Partnership Act (JTPA). The Department of Labor distributes funds for these three programs to the states, and the states in turn distribute funds to designated local areas within the states based on formulas prescribed by WIA. WIA also established performance measures that states and localities must track in order to demonstrate the programs’ effectiveness. The performance measures primarily focus on entered employment rates, employment retention rates, earnings changes, and credential rates. WIA programs provide for three levels of services for adults and dislocated workers: core, intensive, and training. Core services include basic services such as job search and labor market information. These activities may be self-service or may require some staff assistance. Intensive services include such activities as comprehensive assessment and case management, which require greater staff involvement. Training services include such activities as occupational skills training or on-the-job training. WIA requires the establishment of workforce investment boards at the state level and in local areas. The state boards are responsible for a number of functions, including the development and improvement of the statewide workforce investment system and the designation of local areas. The state board assists in the preparation of the state plan and the annual report, both of which are submitted to the Secretary of Labor. The local workforce investment board sets policy for the local area, and its specific duties include developing a comprehensive 5-year local plan and selecting one-stop operators. WIA contains a number of provisions to ensure that individuals with disabilities are adequately served. The most important of these provisions is Section 188, which prohibits any program or activity funded or otherwise financially assisted in whole or part under WIA from discriminating on the basis of disability as well as race, color, religion, sex, national origin, age, or political affiliation or belief. To help states and local areas implement the Section 188 provisions, the Department of Labor issued interim final regulations in November 1999. These regulations, which have the force of law, describe requirements for the recipients of financial assistance under WIA Title I, and for programs and activities operated by the one-stop partners as part of the one-stop system. The regulations also identify how recipients will be held accountable for ensuring nondiscrimination and equal opportunity for individuals with disabilities. The WIA Section 188 regulations contain certain provisions that prohibit recipients of WIA financial assistance from taking certain discriminatory actions. For example, recipients must not: provide significant assistance to a person or entity that discriminates in providing any aid, benefits, services, or training to registrants, applicants, or participants; make a selection for the site or location of a facility that has a impose or apply eligibility criteria that screen out or tend to screen out individuals with disabilities, unless such criteria are necessary for the provision of the aid, benefit, service, training, program, or activity being offered. Further, WIA Section 188 regulations contain provisions that oblige recipients to take certain positive actions to provide comprehensive access to WIA programs and services. For example, these regulations require some recipients of WIA financial assistance—those who are in facilities or parts of facilities that are constructed or altered on their behalf—to make those facilities architecturally accessible. In contrast, recipients of WIA financial assistance who are in unaltered existing facilities are not necessarily required to make those facilities architecturally accessible, but are subject to other requirements for accessibility, known as program access, which specify that a recipient must operate each service, program, or activity so that it, when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. Recipients of WIA financial assistance do not have to make each of their existing facilities or every part of an existing facility accessible to and usable by individuals with disabilities, and can satisfy the accessibility requirements for existing facilities by redesigning equipment, reassigning services to accessible buildings, assigning aides to beneficiaries, and providing home visits, among other options. As part of providing comprehensive access, WIA Section 188 regulations require recipients of WIA financial assistance to take a number of additional actions when administering their programs or activities. Under these provisions, recipients must: take steps to ensure that communications with individuals with disabilities are as effective as communications with others, including providing appropriate auxiliary aids and services where necessary; provide reasonable accommodation to qualified individuals with disabilities who are applicants, registrants, or eligible applicants/registrants for, or participants in, employees of, or applicants for, employment with their programs and activities, unless providing the accommodation would cause undue hardship; make reasonable modifications in policies, practices, or procedures, unless making the modifications would fundamentally alter the nature of the service, program, or activity; provide the most integrated setting appropriate to the needs of qualified individuals with disabilities; and take appropriate steps, such as advertising and marketing, to ensure that they are providing universal access to their WIA financially assisted programs and activities. The regulations also require recipients of WIA financial assistance to establish an administrative structure so that they ensure compliance with WIA’s nondiscrimination and equal opportunity provisions. Each recipient, except small recipients and service providers, must designate an equal opportunity (EO) officer who is responsible for ensuring that the recipient complies with Section 188 regulations. EO officers’ responsibilities include: monitoring and investigating activities by recipients of WIA financial assistance to ensure that they do not violate WIA Section 188 regulations, reviewing written policies to ensure that those policies are nondiscriminatory, and developing and publishing the recipient’s procedures for processing discrimination complaints. Recipients of WIA financial assistance must also provide written notification that they do not discriminate on the basis of disability or on other prohibited bases. This notification must be placed prominently in the facility and distributed through other means. In addition, recipients of WIA financial assistance must collect and maintain data necessary to allow Labor to determine whether the recipient is complying with Section 188 of WIA and the implementing regulations. The Director of Labor’s Civil Rights Center determines which data are necessary. Under WIA Section 188 regulations, the governor of each state is responsible for, among other things: oversight of all WIA financially assisted state programs, ensuring compliance with WIA Section 188 and its implementing regulations, and negotiating with recipients to secure voluntary compliance when noncompliance is found. Moreover, both the Governor and the recipient of WIA financial assistance are liable for all violations of Section 188 unless the Governor has, among other things, established, signed, and adhered to an MOA. The MOA must be in writing and describe how the state programs and recipients of WIA financial assistance have satisfied the requirements of certain regulatory provisions, including those regarding people with disabilities. In addition, the Director of Labor’s CRC has oversight responsibilities under the Section 188 regulations, which include: reviewing the activities of a governor, including the adequacy of the MOA, and investigating and resolving complaints alleging violations of Section 188. As part of its oversight responsibility, CRC, with assistance from ETA and ODEP, issued a compliance checklist on July 25, 2003, to ensure nondiscrimination and equal opportunity to persons with disabilities participating in WIA programs and activities. This checklist, officially known as the WIA Section 188 Disability Checklist, identifies the regulations implementing Section 188 of WIA, including portions of the regulations implementing Section 504 of the Rehabilitation Act, and covers requirements applicable to local area grant recipients regarding the operation of their programs and activities. The checklist is based on the elements required by the MOA and includes lists of questions for each element of the MOA. For some of the elements, the questions are followed by examples of concrete actions that can be taken to ensure compliance with Section 188 requirements. The appendix to the Checklist also includes additional examples of policies, procedures, and other steps that local area grant recipients can take to ensure compliance with Section 188. Labor has awarded grants to facilitate comprehensive access to employment and training programs for persons with disabilities, and local areas and one-stop centers have also made numerous efforts, as well as various degrees of progress, in facilitating comprehensive access to their programs and services. Specifically, ETA has awarded over 100 grants to states and local entities for disability-related activities, such as enhancing comprehensive access to the one-stops. States and local areas have used these grants for a range of efforts, including assessing one-stop architectural accessibility, acquiring assistive technology devices, and increasing staff capacity to provide services to persons with disabilities. Between 2000 and 2004, ETA awarded state and local entities a total of approximately $65 million in competitive Work Incentive Grants in order to enhance one-stops’ capacity to provide programs and services to persons with disabilities, which included improving one-stop accessibility. ETA awarded 113 grants in four rounds between 2000 and 2004. (See table 2.) On the basis of its experience administering the first two rounds of grants, ETA has targeted its specific grant objectives—and, therefore, its resources—to meet the emerging needs that states, local areas, and one- stops have identified in providing programs and services to persons with disabilities.