Task Force on Transforming Training and the Eligible Training Provider List 

In 2023, Jobs for the Future (JFF) and NAWB formed the Task Force on Transforming Training and the Eligible Training Provider List (ETPL), an offshoot of the WTPC, facilitated by former workforce executive Brooke Valle. The task force comprised executives from workforce development boards across the country with special interest and expertise in this topic. Together, through a series of three meetings and subsequent interviews, the task force explored how federal policies can better support existing workforce systems to deliver people-first, equity-centered results for all through training. The resulting principles and recommendations outlined in this report lean into the power of the nation’s workforce development system as a whole while remaining locally responsive and data-driven.1

The recommendations in this brief are those of the WTPC Task Force on Transforming Training and the ETPL and not necessarily those of JFF or NAWB. We thank the participating leaders for their time and expertise in providing the following insights. 

Transforming Training and the ETPL

While WTPC members employ a full suite of training approaches, including on-the-job training (OJT), individual training accounts (ITAs), customized training, incumbent worker training, apprenticeship, and pre-apprenticeship, members confirmed that most of their organizations’ training dollars are deployed through ITAs to providers on the ETPL.

Local workforce areas’ reliance on ITAs for the provision of training and on the ETPL for identifying eligible training providers has resulted in challenges that must be solved to improve the ability to meet participants’ skill needs and to work in more collaborative, streamlined ways with training partners. However, even before solving for these challenges, it is critical to recognize that current funding levels are not sufficient to provide jobseekers or underemployed workers with the training pathways or meaningful supportive services they need to progress into careers that offer family-sustaining wages. In fiscal year 2023, the three formula grants in WIOA, which is the main source of support to help jobseekers obtain skills needed for in-demand occupations, were funded at about $3.3 billion. That, in inflation-adjusted terms, is down about 50% from fiscal year 2000. In fact, investment in workforce development reached its peak in the late 1970s, and to match that level now, policymakers would need to increase annual WIOA state formula allotments to about $35 billion, a significant portion of which would be deployed to provide training and other direct services.

Design Principles for Transforming Training

These principles outline the core strategies for increasing access and achieving positive results for diverse populations. Specific recommendations follow for each principle.

Broaden the definition of training to include career readiness such as digital and financial literacy, business communications, problem-solving, and other skills essential for success in today’s job market.

Increase investment in pathway programs that provide stackable, competency-based, portable credentials, and transferable skills that accelerate advancement toward family-sustaining wages.

Provide participants with transparency and informed choice through increased data sharing and relevant, up-to-date information on training program results that are contextualized and easy to understand.

Reduce the administrative burden to encourage participation of high-quality providers in the workforce training ecosystem and increase staff time that can be dedicated to the delivery of other crucial services.

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Broaden the Definition of Training

The need for skills training remains central to workforce development, but how and where skills are attained is becoming less important in a skills-based labor market. Workers require agile, human-centered learning approaches that give credit for prior learning, assess skills gaps, and offer low-friction ways to quickly obtain needed knowledge and experiences. Meanwhile, employers want individuals who have both the technical know-how and the personal communication, decision-making, and analytical skills needed to be ready to work. 

Digital skills are also central to most careers, from manufacturing to marketing, as virtual communications, data analytics, and automation increasingly shape the way work is performed. To equip individuals for the workforce and meet the needs of employers, funding must be more portable and flexible, allowing learners to draw down what they need, when they need it. The current training structure must also shift to a more immersive support model that fully leverages technology to deliver just-in-time, stackable, competency-based learning, portable credentials, and transferable skills.

• While a wide variety of training mechanisms can be used to equip individuals with critical skills, training is defined narrowly in the WIOA statute and in guidance from the U.S. Department of Labor (DOL) on ITAs and the ETPL, restricting learning that is not directly tied to an industry-recognized postsecondary credential, even if it contributes to an individual’s success.
  
  Recommended actions: Task force members agreed that the definition of training in workforce development programs (allowable training expenditures) should more closely resemble what qualifies as education expenses outlined in Pell Grants 20 U.S. Code § 1087ll—Cost of Attendance, which includes tuition and fee payments, books, supplies, prior learning assessments, related equipment required for coursework, room and board, transportation, and other necessary expenses. Alignment of the Pell and WIOA definitions could also facilitate braiding funding to cover the full costs of course completion. Training accounts should be associated with the individual, similar to Pell Grants, and be awarded for training and training-related activities as the individual progresses through a pathway to an in-demand job. Pauses between training courses for employment or other life circumstances (e.g., working as a phlebotomist before taking a course to become a lab technician) should not impede the individual’s access to the funding. Activities identified through an Individual Employment Plan (IEP), including the acquisition of workforce readiness skills, the building of specific competencies, or the earning of a credential, should be an eligible use of training funds. This should include expenses incurred in test preparation, examination fees, prior learning assessments, and related preparatory tasks.
• Training programs tend to focus on occupational skills over workplace readiness, digital literacy, language skills, coaching, and supportive services such as mental health, transportation, and child care, all of which are critical for success. They often lack the necessary customization to accommodate an individual’s lived experience or flexibility to heed the order in which these resources are needed by the person.
  
  Recommended actions: Task force members agreed that permissible training in workforce programs should include workplace readiness, digital literacy, and other essential skills that are identified by employers as necessary for in-demand employment and included in the individual’s employment plan. Further, if the skills are necessary for a living-wage job, these training services should not be required to be provided in combination with occupational skills training or tied to an industry-recognized credential. WTPC members also stressed that local boards should be able to use mechanisms other than ITAs, OJTs, or Customized Trainings (such as through classes offered in one-stop career centers) for work readiness, basic English skills, or digital literacy that are required by employers. The acquisition of such skills should count as measurable skills gains in performance, and staff time for the provision of these training and training-related services should count toward training costs. This would provide needed flexibility and better enable local boards to provide critical skills to broader populations.
• A significant portion of each local workforce board’s WIOA allocation is used to provide direct services to the community. An increasing number of states have thresholds or required percentages of the funding that must be allocated to training, but there is currently no statutory requirement for the amount that must go toward training. Such a requirement could have far-reaching implications for the system if implemented without considerations for how training is defined and without the career navigation and supportive services that are required for participant success.
  
  Recommended actions: In addition to an expansion of the definition of training, as described above, task force members stressed the importance of providing credit to workforce boards for training that is funded through non-WIOA dollars if a percentage requirement should be added. Task force members stressed that leveraged resources should remain flexible, however, and not be subjected to performance or other WIOA statutory requirements.
• Current ITAs and OJT programs are not structured with non-W2 employment in mind. The entrepreneurial skills that are necessary for success in independent work and the gig economy are increasingly in demand, particularly for younger workers and new Americans, and as the share of American workers in non-W2 jobs has grown. According to a 2023 Bankrate survey, 39% of American adults have a side hustle and 28% believe they’ll always need one to make ends meet.3 In addition, a survey by McKinsey found that 36% of respondents identified themselves as independent workers in 2022, which equals about 58 million American adults. The growing percentage of workers in non-W2 employment makes it crucial to use training dollars to support all on-ramps to success, including entrepreneurship.
  
  Recommended actions: Task force members agreed that entrepreneurial training is an important form of training that should be exempted from credential attainment metrics in workforce development and other performance measures, if a business can demonstrate that the training is necessary to help it survive, hire staff, or expand its operations. Metrics that could be used instead of credential attainment to demonstrate this include pre- and post-intervention income or profit statements, job-creation statistics, sales reports, increases in client counts post-intervention, or client net promoter scores.
• Current credential requirements are largely representative of traditional education pathways based on course credits or semester completion and do not capture stackable competencies that can be rapidly gained through the use of technology or other innovative training-delivery mechanisms. The current standards ignore micro-credentials, which provide a stackable mechanism to deliver just-in-time training on a specific competency, such as data analytics, automation, visualization, negotiation, or crisis management, needed by a wide variety of employers or specific to a single industry. This bite-sized learning also enables the workforce system to partner with employers in capturing emerging skills, such as query development for AI tools, at a pace aligned to industry’s needs.
  
  Recommended actions: Task force members stressed that local boards should be able to use ITA funds to provide opportunities for the attainment of all types of skills required by employers. Specifically, micro-credentials should be included in the definition of industry-recognized postsecondary credentials, and the DOL should provide guidance on how micro-credentials can become industry-recognized, recommendations for ensuring the quality of such credentials, as well as suggestions for how micro-credentials can stack toward higher-level credentials. The DOL should also provide guidance on how local boards can document and receive credit for a modularized training approach, since individuals may complete multiple micro credentials, certificates, or licenses over varying periods of time based on employer need and training availability. This is particularly true for emerging fields such as climate and artificial intelligence that are evolving at a rapid pace and creating demand for new competencies. The DOL should encourage states and local boards to pursue the use of technology to advance upskilling interventions, that are employer-led, tech-enabled, and digitally delivered to facilitate lifelong learning and worker advancement.
• The measurable skills gain (MSG) metric tracks advancement toward a participant’s employment goals as outlined in their IEP, but the current definition of MSG does not incorporate many of the preparatory steps or barrier removal actions that are critical to success. This situation can disincentivize local workforce boards from serving individuals who require extensive pre-training support, since these efforts are not tracked or incentivized. For example, a person who has been incarcerated and is returning to the community may need to obtain a driver’s license or complete a sober-living program as a prerequisite for entering a program for acquiring a commercial driver’s license. Similarly, an internationally trained nurse who immigrates to the United States and plans to return to a career in nursing may need to complete English-language coursework prior to filling any course gaps required to re-credential in the United States.
  
  Recommended actions: Task force members concluded that the DOL should adjust the regulations to not only allow the prerequisites that are directly connected to an individual’s credential pathway to be counted as an MSG, but also to capture data on barrier removal and thus incentivize the boards to support all workers, regardless of their needs. This would provide better insight into the advancement of individuals and expand the reporting on the depth of support that is required for participants to successfully complete training and enter a career pathway leading to a quality job.

Increase Investment in Career Pathways

While skills-focused training is critical to the advancement of U.S. workers, our current education, workforce, and employment systems remain siloed and inflexible. Training is largely centered either on short-term training or on traditional two-year degrees pursued in classroom settings, with a lack of true support for career pathways. Current funding for workforce development and occupational skills training is largely insufficient to allow for participants to engage in pathways to family-supporting careers. The workforce system can serve only a subset of those who need longer-term training or supports. Many positions that serve as the entry point of a career pathway, such as home health caregiver or certified nursing assistant (CNA), don’t pay a high enough wage to either cover the cost of additional training or support an individual in pursuit of career advancement and a family-supporting career.

• WTPC members said training can stretch out over years if participants must work full-time while completing training. This may require them to pause and restart their training, causing them to fall further and further behind, in both skill attainment and potential earnings growth. Adequate and flexible funding for skills development and supports can make the difference between a participant successfully completing training and transitioning into the workplace or getting stuck along the way due to life circumstances.
  
  Recommended actions: To encourage longer-term training strategies, such as career pathways approaches to skills development, task force members underscored the need for significant increases in funding for career navigation, skills training, and support services for individuals in training. As earlier noted, if funding for these services had kept up with inflation since the 1970s, workforce development funding would equal at least $35 billion today. In addition to training, workforce systems should be allowed to provide stipends to adults enrolled in eligible training programs, including participants who are low-wage incumbent workers. Currently, needs-based payments are limited to individuals who are unemployed and have exhausted unemployment insurance.
• Robust pathway programs can require multiple training courses, work experiences, and extensive supportive services to assist individuals in moving from entry-level positions to jobs that provide living wages. While lack of funding and supportive services is part of the challenge, the current performance measures in WIOA also disincentivize workforce boards from retaining individuals on their caseloads for the entire duration of pathways to family-supporting careers. Boards do not receive credit for entered employment and wages until the individual is exited from the program, despite the fact that work experience might be a vital part of the individual’s success and essential to progression to the next wage level. For example, an individual pursuing a tech pathway may need to gain experience on the support desk to successfully complete a cloud certification and move into a living-wage technology job.
  
  Recommended actions: To encourage pathway approaches in education and workforce development programs, the task force agreed that performance metrics should be adjusted in ways that encourage local boards to keep individuals enrolled in WIOA-funded training beyond attainment of a first job if they are pursuing a career pathway to a family-supporting career. To accomplish this, WIOA’s performance measures should allow workforce systems to receive performance credit for participants’ initial employment, wages, credential attainment, skills gains, and subsequent employment along approved career pathways—without the current requirement that participants must first be exited from the program before entered employment and wages are counted.
• Many occupations that contribute to public health, safety, or basic quality of life, such as child care, mental health care, or refugee resettlement support, lack talent that is both diverse and highly skilled, often because of competition and wage pressures. Cultural competency, language fluency, and communications skills are needed to provide high-quality care, but organizations that are small, have nonprofit status, or maintain slim profit margins can find it difficult to invest in talent development, attraction, and retention.
  
  Recommended actions: Task force members agreed that jobs that contribute to the public good are important to society and that dedicated funding should be provided to support this sector, whether through a new federal allocation, a collaborative fund supported by the departments of Labor, Education, and Commerce, or through the encouraged use of state set-aside funds to leverage support for public-good pathway programs. Under such approaches, each state’s workforce system, in collaboration with economic development and other key agencies, would designate these pathways as part of the state’s sector strategy to ensure that participants and employers can benefit from successful career pathways in public-good occupations. This work should be coupled with policies for raising the wages of these occupations such as through tax incentives, student loan forgiveness, or other mechanisms. 

Provide Clients with Transparency and Informed Choice

WIOA outcome measures are important for understanding how workforce systems support education completion and employment. They do not, however, provide user-friendly information to help consumers make informed choices about the occupations or training choices they should pursue. Current reporting was designed for program oversight and compliance rather than to help clients, employers, or even workforce development boards make informed choices.

Data on training outcomes suffers significant lag time, is often incomplete, and the resulting metrics lack context, making it difficult for consumers to understand. Data sharing across federal and state systems is inconsistent, and the lack of system integration between states’ departments of education, labor, and commerce can cause delays, require duplicative reporting, and limit visibility into participant outcomes. 

Current data often lacks the breakdown of completion by race, ZIP code, neighborhood, or information on prior learning experience, which would help interested individuals determine whether a program has successfully supported individuals with similar needs and life circumstances. Program information also does not consistently include information about whether programs are specifically designed for a particular population, such as contextualized English-language learning and technical skills, to enable clients to better compare course offerings.

• Detailed, disaggregated data are necessary to enable participants to understand the full range of available options and their corresponding outcomes; and to provide the system and its providers with a more transparent and holistic view of the impact that the workforce system and its services have on participants.
  
  Recommended actions: The U.S. should create a standard report template, in the style of the Consumer Reports organization, for training that all states can use and that couples labor-market data, employer insights, and contextualized participant results, all reported on a regular cadence. Workers need to understand whether the training they are considering has enabled others to obtain a job in the field, how much time it took for individuals to complete the training, the level of effort required by a program, how the wages earned by program completers compare to the living wage for their area, and the influence that other life circumstances may have had on the available completion data. Reports should include information on which employers are hiring graduates from specific programs, to provide insight into the value that the credential has in the local market. Finally, incorporation of participant reviews of programs would put power back in the hands of the participant and incentivize providers to pay close attention to the full student experience. Policymakers should incentivize states and local areas to report on training that is delivered to WIOA participants but that is funded through other sources in order to better understand the full suite of training available to workers.
• Workforce development agencies and educational institutions share many of the same objectives for equipping individuals for success, as well as for clients participating in their programs, yet their data sets are often siloed or have greatly restricted access, which limits the ability of workforce service providers to understand the holistic impact that training has on the life of an individual.
  
  Recommended actions: Task force members expressed strong support for requiring states to match education and workforce data and provide the results to local workforce boards, thus ensuring that all boards have the most holistic, up-to-date information on training outcomes. Additionally, governors, with the advice of the respective agencies and state board, should require data-sharing agreements between states’ departments of labor, economic development, justice, corrections, education, and veteran affairs, as well as other social service agencies, so as to facilitate the alignment of training objectives, accountability structures, and program governance models. Incentives should be provided, including investments in infrastructure and performance-based awards, for development of shared-data goals, integrated reporting, longitudinal data systems, and predictive analysis. This would be aligned with the Foundations for Evidence-Based Policymaking Act and could build off of the ongoing effort to create a national secure data service by the Advisory Committee on Data and Evidence Building, National Secure Data Service work along with DOL’s Enterprise Data Strategy. For example, policymakers should require integration or linkage between the Department of Education’s College Scorecard and ETPL performance reporting so that clients can simultaneously access a full picture of an institution’s outcomes.
• Analytics capabilities are too often siloed rather than centralized or regionalized, although the latter model would mean that local boards could maximize human and capital investments, reduce the administrative burden on providers by standardizing data collection, and better analyze trends and identify synergies. Such a shared service model could produce meaningful reporting that would let various audiences (e.g., boards, participants, providers, researchers) make decisions based on program results.
  
  Recommended actions: The DOL should encourage states to explore hub-and-spoke models that can deliver to local boards the necessary infrastructure and data analytics capabilities to enable more robust reporting on learning outcomes. The DOL could provide incentives for such models, such as targeted grant dollars to support initial infrastructure build-out, high-performing board awards for integrated reporting, or the option to allocate regional planning investments toward such a centralized entity when the entity carries out required reporting on labor-market information. As stated in a recent report from the Job Quality Measurement Initiative (a collaborative effort between the DOL and more than 70 experts from across the United States), called “Reimagining Job Quality Measurement,” “prioritizing the creation of an intergovernmental research and analytics consortium of policy and data experts from the public and private sector can rapidly build state and local data capacity to drive more effective, equitable policies and programs.”

Reduce Administrative Burden

The ETPL is one of the primary mechanisms used to connect workers with high-quality training, and yet many state processes for enrollment on the ETPL are lengthy and difficult to navigate. Extensive paperwork, delays in processing, and a lack of regular reporting on performance create administrative challenges. Additionally, the lack of processes to centrally add training providers that operate across states can disincentivize the participation of high-quality training institutions and reduce the choices available to participants.

• Community colleges are required partners for workforce development boards.6 Task force members stressed that it is important to encourage collaboration, reduce costly administrative processes, and give colleges the time to deliver coursework and provide required reporting on outcomes. Automatically adding community colleges, with their published courses and course costs, to the ETPL would reduce the administrative burden and eliminate markup of costs while allowing local boards to categorize colleges as “inactive” for the purposes of funding if they fall below performance thresholds.
  
  Recommended actions: To encourage robust training provider participation, task force members support the automatic addition of accredited community colleges and their programs to the ETPL. Under such circumstances, states would be required to add the community colleges to their ETPL, the community colleges would still be required to report on students who participate in relevant programs, and state labor agencies would be responsible for performing the necessary data matching (e.g., use of unemployment insurance wage records matched to privacy-protected student identifiers) to publish timely program outcomes. Local boards would maintain responsibility for determining whether programs of study meet local in-demand requirements and for holding colleges accountable for workforce outcomes. It is critical that these outcomes be made available to the public in user-friendly formats so individuals can make informed career and training choices. Task force members also stressed that states and local boards should be authorized to suspend training provider eligibility if they do not consistently perform in serving WIOA participants. Similarly, the task force supports providing the DOL with the authority to create a federal approval process for the addition of national training providers to the ETPL list. This approval could then be cascaded to the states, removing the administrative burden for the training institution to apply in each state. States should retain the ability to categorize the provider as “inactive” for the purposes of funding if the provider consistently falls below the state’s performance metrics.
• The implementation of initial and subsequent eligibility for the ETPL varies greatly from state to state. Data-collection processes, review periods, performance requirements, frequency of reporting, and the organization that holds the authority to approve or deny applications are all unique to the individual state.
  
  Recommended actions: Task force members support uniform standard and conditional eligibility requirements for ETPL providers. States should streamline the application process, removing any duplicative collection or data matching, and issue eligibility determination within 30 days of application submission. States should also revise reporting requirements to include information on the credential issuing entity, the degree to which it is recognized by the employer community, and the associated skills and earnings that participants can attain upon credential achievement. Additionally, DOL should provide technical assistance and training for states looking to implement business process transformation to modernize or adapt their ETPL processes.

Conclusion

The United States must invest in the skills of America’s workers and make changes in how education and training are provided to meet the needs of today’s students, jobseekers, workers, and employers. Skills training in combination with work-based learning, can provide a powerful mechanism to support the advancement of individuals toward good jobs. However, policy adjustments that better support pathways for workers, that take a more expansive view of training, and that incorporate non-W2 workers into the existing learning structure are necessary. Advancements in data sharing, the modernization of systems, and the adoption of innovative ways to report and share data and to determine the quality of services will also be important levers in achieving equitable outcomes for learners. With dedicated funding and support, workforce training can be a crucial pivot point in the trajectory of an individual’s life, supporting future career advancement and growth. 

Endnotes

1. For definitions of the terms diverse populations, people-first, equity-centered and locally responsive see the first paper in the series called “Improving Services and Outcomes for Diverse Populations in America’s Workforce Development System” found at https://www.jff.org/idea/improving-services-and-outcomes-for-diverse-populations-in-americas-workforce-development-system/
2. U.S. House of Representatives website, “20 USC 1087ll: Cost of Attendance,” https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title20-section1087ll&num=0&edition=prelim
3. Lane Gillespie, “Survey: 39% Have a Side Hustle, and 44% Believe They’ll Always Need One,” Bankrate, May 24, 2023, https://www.bankrate.com/personal-finance/side-hustle-survey/
4. André Dua et al., “Freelance, Side Hustles, and Gigs: Many More Americans Have Become Independent Workers,” McKinsey & Co., August 23, 2022, https://www.mckinsey.com/featured-insights/sustainable-inclusive-growth/future-of-america/freelance-side-hustles-and-gigs-many-more-americans-have-become-independent-workers
5. U.S. Department of Labor, “Training and Employment Guidance Letter No. 03-18,” August 31, 2018, https://www.dol.gov/agencies/eta/advisories/training-and-employment-guidance-letter-no-03-18
6. The Higher Education Act of 1965, at 20 USC 1058(f), defines the term: For the purpose of this part, the term “junior or community college” means an institution of higher education 1) that admits as regular students persons who are beyond the age of compulsory school attendance in the state in which the institution is located and who have the ability to benefit from the training offered by the institution; 2) that does not provide an educational program for which it awards a bachelor’s degree (or an equivalent degree); and 3) that a) provides an educational program of not less than two years that is acceptable for full credittoward such a degree, or b) offers a two-year program in engineering, mathematics, or the physical or biological sciences, designed to prepare a student to work as a technician or at the semi-professional level in engineering, scientific, or other technological fields requiring the understanding and application of basic engineering, scientific, or mathematical principles of knowledge.