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United States General Accounting Office: 
GAO: 

Report to Congressional Requesters: 

April 2002: 

Workforce Investment Act: 

Youth Provisions Promote New Service Strategies, but Additional Guidance
Would Enhance Program Development: 

GAO-02-413: 

Contents: 

Letter: 

Results in Brief: 

Background: 

WIA’s Youth Provisions Implemented but Not without Some Challenges: 

Educators Participated on Youth Council and Delivered Services but 
Remained Tentative Partners: 

State and Local Factors Facilitated Implementation, but Some New 
Requirements Inhibited Service Delivery: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I Comparison of Key Youth Provisions under WIA and JTPA: 

Appendix II Comments from the Department of Labor: 

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Comparison of Youth Services under WIA and JTPA: 

Table 2: Youth Council Membership and Responsibilities: 

Table 3: Selected Strategies Youth Councils Developed to Link with 
Education: 

Figures: 

Figure 1: Size of Youth Councils: 

Figure 2: Strategies to Attract Youth to One-Stop Centers: 

Figure 3: Percentage of Local Boards with a Youth Council Whose Members 
or Chair(s) Represented Various Categories of WIA-Required and Optional 
Personnel: 

Abbreviations: 

DOL: Department of Labor: 

JTPA: Job Training Partnership Act: 

RFP: request for proposal: 

STW: School-to-Work: 

TANF: Temporary Assistance for Needy Families: 

WIA: Workforce Investment Act: 

[End of section] 

United States General Accounting Office: 
Washington, DC 20548: 

April 5, 2002: 

The Honorable Edward M. Kennedy: 
Chairman, Committee on Health, Education Labor, and Pensions: 
United States Senate: 

The Honorable James M. Jeffords: 
United States Senate: 

The Workforce Investment Act (WIA) of 1998[Footnote 1] provides states 
and local areas an unprecedented opportunity to substantially change 
the way youth workforce development services are configured and 
delivered. Historically, programs designed to assist at-risk youth to 
attain employment and self-sufficiency were a patchwork of short-term, 
stand alone services delivered by a loosely coordinated network of 
providers, often resulting in redundancies and inefficiencies. WIA aims 
to broaden the job training and placement focus of its predecessor, the 
Job Training Partnership Act (JTPA), by requiring states and localities 
to create a more comprehensive workforce investment system that 
addresses youth’s many development needs. In addition, WIA requires 
states and localities to streamline the delivery of at least 17 
federally funded employment and training services—most of which may 
include some youth services[Footnote 2]—that are administered by the 
Departments of Labor, Education, and other agencies through one-stop 
centers, physical sites that serve as gateways to information and 
services found in communities.[Footnote 3] Through its holistic 
approach to serving at-risk youth, WIA, its implementing regulations, 
and Department of Labor (DOL) guidance call for a comprehensive youth 
development system[Footnote 4] that is linked more closely to local 
labor market needs and community youth activities, emphasizes 
comprehensive service strategies to engage youth year-round, and 
requires parents, program participants, and other members of the 
community with experience in youth services to provide input on youth 
programs. To ensure youth programs are tailored to the needs of youth 
and the community, WIA promotes partnerships among diverse programs and 
community representatives, in part, through their participation on 
newly created state and local workforce investment boards and youth 
councils. The law requires youth councils to plan and coordinate youth 
programs as well as recommend and oversee youth service providers. The 
law also requires youth councils to establish linkages with educational 
agencies for providing services to young participants. 

To more fully assess how youth workforce investment activities are being
carried out, you asked us to (1) determine the implementation status of
WIA’s youth provisions including establishing youth councils and a 
network of service providers; (2) recognizing that strong relationships
between youth development and education systems are a crucial 
component of a comprehensive youth service strategy you also asked us to
examine how youth councils have established linkages with the education
community; and, (3) determine the factors that affected the 
implementation of a new youth development system and their implications
for service delivery. 

To gather information to respond to these questions, we surveyed 
directors of each local workforce investment board nationwide[Footnote 
5]—611 in all—and received responses from 505 (83 percent) of them. We 
reviewed local board directors’ questionnaire responses for consistency 
and in many cases contacted them or their staff to resolve 
inconsistencies, but we did not otherwise verify the information 
provided in the questionnaire responses. To further understand 
implementation status, linkages with education, and factors affecting 
implementation, we visited 9 local workforce investment areas in five 
states: California, Florida, New Jersey, Wisconsin, and Wyoming. 
[Footnote 6] We selected these states on the basis of a variety of 
state-specific factors such as geographic location. With the exception 
of Wyoming, we also selected states because of relatively high numbers 
of workforce investment areas and disadvantaged youth, relatively high 
levels of WIA youth funding and state per pupil education 
expenditures,[Footnote 7] and, in most cases, early WIA implementation 
and the presence of state legislation regarding school-based career 
programs. We chose local sites in each state on the basis of the state 
workforce officials’ recommendation of one urban and one rural area 
that had either demonstrated promising practices or was further along 
in implementation than other areas. We interviewed officials 
representing local boards, youth councils, one-stop centers, youth 
service providers, and education agencies. We also interviewed state 
workforce investment and education officials in each of the five 
states. In addition, we conducted telephone interviews with officials 
from 20 state workforce investment boards or agencies. We selected 
states to interview that represented variations in the same factors 
that we used to select states for site visits. We also interviewed 
officials from the DOL and national associations. Our work was 
conducted between February 2001 and February 2002 in accordance
with generally accepted government auditing standards. 

Results in Brief: 

Nearly all of the local workforce investment boards nationwide
established a youth council and a network of youth service providers—but
not without challenges. Nationally, a majority of youth councils 
included the required members and nearly all councils were active by 
July 1, 2000, when the first program year under WIA took effect. Local 
boards also competitively selected youth service providers and 
developed strategies for connecting youth to the one-stop centers. Most 
boards reported that youth received WIA services directly through 
contracted service providers rather than through the one-stop centers. 
For example, a program offered at one provider’s facility in rural 
Wisconsin combined academic learning and work experience by having out-
of-school youth build or refurbish low-income housing while preparing 
for their high school equivalency credential. However, local boards 
found it challenging to get parents and youth to participate on youth 
councils. Also, a number of local areas found it difficult to identify 
and select youth service providers through the competitive selection 
process because of low numbers of providers responding to requests for 
proposals. Finally, getting youth to visit the typically adult-focused 
one-stop centers was often a demanding task. Many local boards 
exercised the flexibility allowed under WIA by expanding the youth 
council to include representatives from private industry, establishing 
youth-only one-stop centers that were electronically linked with 
providers and other one-stops, and leveraging additional non-WIA
resources to expand their youth service capacity. 

Youth councils established linkages with the education community by
including local school districts and existing school-based career 
program representatives in their membership or as youth service 
providers. Nationwide, representatives from school districts or school-
based career programs were among the most frequently represented 
members on youth councils, even though not required under WIA. In some 
local areas we visited in California and Florida, the existing school-
based career program formed the foundation for the new WIA youth 
council. Moreover, secondary and postsecondary schools were contracted 
to deliver youth services such as mentoring and occupational skills 
training. Educators were also connected to the one-stop centers by 
bringing high school students into the centers for job fairs or by 
having center staff administer youth skills assessments at schools. In 
some communities, however, the education and workforce investment 
systems lacked a shared vision for youth development. In particular, 
some educators were hesitant to broaden their role in youth development 
beyond traditional academics and saw few financial incentives to 
partner with the youth council. 

Two factors facilitated the building of a new youth development system 
at the state and local level and improved coordination and delivery of
services—having experience in collaborative efforts among various public
and private youth-serving agencies and placing priority on youth 
development. However, we found three legislative requirements that 
impeded implementation progress or adversely affected service delivery.
First, eligibility documentation requirements may have excluded eligible
at-risk youth from WIA services, in part because documentation to verify
eligibility was difficult to obtain and verification was resource-
intensive for staff and service providers. A second challenge was to 
recruit and retain sufficient numbers of out-of-school youth to meet 
the requirement that 30 percent of local WIA youth funds be spent on 
these youth. Third, ambiguous definitions and lags in data availability 
complicated the measurement and reporting of some WIA youth performance 
indicators and resulted in inconsistencies in reporting and comparing 
outcomes within and across states. 

To support the development of a youth workforce investment system, we
are recommending that DOL provide guidance and assistance to address
specific concerns identified by state and local implementers. We are 
also recommending that DOL clarify the definition of the skill 
attainment performance indicator for younger youth (14-18 years of 
age). In its written comments, DOL concurred with our findings and
recommendations. 

Background: 

WIA repealed, after 16 years, the Job Training Partnership Act, and in
doing so, introduced various reforms to the coordination and delivery of
federally funded employment and training services. Program year 2000
was the first year in which states and localities operated programs 
under WIA.[Footnote 8] WIA’s reforms affected youth as well as adult 
and dislocated worker services.[Footnote 9] Among the most significant 
changes to youth services was the consolidation of JTPA’s two 
separately funded youth programs—the Title II-B Summer Employment and 
Training Program and the Title II-C year-round training program—into a 
single year-round program under Title I-B of WIA with a fiscal year 
2001 funding level of $1.4 billion. DOL estimated 721,000 youth 
participants would be served in program year 2001. JTPA’s summer 
employment program, with a 1999 funding level of $870 million, was 
significantly larger than the JTPA year-round program funded at $130
million. As a result of consolidating JTPA’s two youth programs, summer
employment became one of the many youth services under WIA. 

Youth services under WIA are intended to be more comprehensive and
longer-term than under JTPA, while offering local areas the flexibility 
to tailor services to meet the needs of individual youth. While both 
JTPA and WIA required that youth receive appropriate services based on 
an assessment of their service needs, WIA mandated that 10 youth 
services, referred to as program elements, be made available to all 
eligible youth. (See table 1.) Under JTPA, several of these program 
elements were either optional or not present. For example, leadership 
development and the 12 months of follow-up services upon program 
completion are new under WIA. 

Table 1: Comparison of Youth Services under WIA and JTPA: 

Youth Services: 

WIA: 

* Required: assessment, individual service strategy, preparation for 
postsecondary education or employment, strong linkages between academic 
and occupational learning, preparation for unsubsidized employment, 
connections to intermediaries with links to local labor market, 
information, and referral. 

* All 10 program elements must be made available to youth: (1) 
tutoring, study skills training, instruction leading to completion of 
secondary school, including dropout -prevention strategies (2) 
alternative secondary school services, (3) summer employment linked to 
academic and occupational learning, (4) paid and unpaid work experience
including internships and job shadowing, (5) occupational skills 
training, (6) leadership development which may include community 
service and peer-centered activities encouraging responsibility, (7) 
supportive services, (8) adult mentoring during program participation 
and at least 12 months subsequently, (9) at least a 12-month follow-up 
upon program completion, and (10) guidance and counseling including
drug and alcohol abuse counseling and referral. 

JTPA: Year-round services: 

* Required: assessment, individual service strategy, training in basic, 
occupational, and work maturity skills, work experience, and supportive 
services, information, and referral. 

* Optional program elements include: (1) tutoring, (2) alternative high 
school, (3) instruction leading to high school completion or 
equivalent, (4) mentoring, (5) limited internships, (6) training or 
education combined with community and youth service, (7) entry 
employment experience, (8) school-to-work services, (9) school-to-
postsecondary education services, (10) school-to-apprenticeship 
services, (11) counseling and referral, (12) services encouraging 
parental and other significant adult involvement, and (13) cash 
incentives and bonuses based on program attendance and performance. 

JTPA: Summer services: 

* Required services include: assessment, individual service strategy, 
basic and remedial education, work experience, occupational training, 
job referral and placement, supportive services, followup services as 
appropriate. 

Source: Workforce Investment Act and Job Training Partnership Act. 

[End of table] 

In addition to merging JTPA’s summer and year-round programs, WIA
targets services to a youth population that is potentially lower income 
than that targeted under JTPA. While both programs included the same 
income eligibility ceiling, JTPA also granted eligibility to youth who 
participated in the free- and reduced-price school lunch program, which 
had a higher income eligibility ceiling than that under WIA. JTPA also 
allowed a greater percentage of non-low-income youth than WIA, 10 
percent compared to 5 percent. Furthermore, by requiring that 30 
percent of WIA youth funds be spent on out-of-school youth, WIA targets 
young people who are no longer attending any school, including an 
alternative school. While JTPA’s year-round program also required 
serving some out-of-school youth, the summer employment program did 
not. For more information on how WIA and JTPA differ in their key youth 
provisions, see appendix I. 

The WIA youth appropriation consists of formula funds, which states
receive and allocate to their local workforce investment areas, and 
Youth Opportunity Grants,[Footnote 10] which DOL awards to local areas 
on a competitive basis. States are required to allot at least 85 
percent of the youth formula funds to local areas based on criteria 
that include the number of disadvantaged youth in each local area 
compared to the total number of disadvantaged youth in the state. In 
addition, states shall set aside up to 15 percent of the youth funds 
for statewide youth activities, which include disseminating a list of 
eligible youth service providers. WIA permits states to combine the set-
aside from the youth allotment with similar set-asides from their adult 
and dislocated worker allotments. However, local boards are prohibited 
from transferring formula funds from the WIA adult and dislocated 
worker programs to the youth program or vice versa. 

In addition, new under WIA is the requirement that youth services be 
made available through the one-stop system. One-stop centers can serve 
as the entry point for all youth in the local area, providing universal 
access to information and services. These centers are gateways to 
services for WIA-eligible youth as well as services funded for non-
eligible youth who may also receive services at one-stop centers such 
as job searches, career exploration, use of career center resources, 
and information on and referrals to other youth providers. 

WIA also strengthens accountability by establishing younger and older
youth[Footnote 11] performance indicators for all youth receiving WIA 
services, including those receiving summer employment services, and by
establishing customer satisfaction indicators for participants and
employers. In contrast, JTPA did not establish any performance 
indicators for the summer employment and training program. States must 
negotiate and reach agreement on their expected levels of performance 
with the Secretary of Labor. Similarly, local areas must negotiate and 
reach agreement with the governor on local levels of performance. 
Furthermore, WIA holds states accountable for achieving their 
performance levels by linking them with financial incentives or 
sanctions. 

Lastly, WIA youth activities are coordinated through newly created state
and local workforce investment boards.[Footnote 12] The state board is 
established by the governor to carry out statewide youth activities and 
to develop the state strategic plan. The 5-year plan must describe the 
state’s strategy for providing comprehensive services to eligible 
youth, identify criteria local boards use to award grants and select 
providers, and describe coordination with other youth programs. The 
majority of state board members, including the board chair, must come 
from private business. The governor also certifies local boards to, 
among other duties, develop the local plan and select one-stop 
operators and youth service providers. Like state boards, the majority 
of local board members and the chair must come from private business. 
Among WIA’s most significant reforms is the requirement that local 
boards establish a youth council[Footnote 13] as a subgroup of the 
board, to coordinate and oversee the local WIA youth program (see table 
2). While the youth council’s membership must reflect a broad cross-
section of community representatives, youth councils do not require 
membership from educational entities. 

Table 2: Youth Council Membership and Responsibilities: 

Required membership: 

* Representatives of the local board with special interest or expertise 
in youth policy. 

* Youth service agencies including juvenile justice and law 
enforcement. 

* Public housing authorities. 

* Parents of eligible youth. 

* Former participants and representatives of organizations with 
experience in youth activities. 

* Job Corps as appropriate[A]. 

* Others as deemed by the local board chair. 

Responsibilities: 

* Coordinate youth activities in the local area. 

* Develop portions of the local five-year plan related to eligible 
youth. 

* Recommend eligible youth service providers to the local board for its
approval. 

* Oversee eligible providers. 

* Carry out other duties authorized by the local board chair such as 
establishing linkages with educational agencies and other youth 
entities. 

[A] Job Corps is a residential program that provides job training and 
job-readiness skills to disadvantaged at-risk youth, ages 16-24. Not 
all local workforce investment areas have a Job Corps program. 

Source: Workforce Investment Act. 

[End of table] 

While not a mandatory member of workforce investment boards and youth
councils, state and local school-based career programs, including 
School-to-Work[Footnote 14] (STW) programs, complement the youth 
development system envisioned under WIA by linking education with 
workforce and by engaging a broad range of community representatives in 
designing and implementing a comprehensive, integrated system of 
education and workforce preparation that reflects local labor market 
needs. Like WIA, STW promotes classroom teaching that is more closely 
linked with the workplace to help both in-school and out-of-school 
young people prepare for postsecondary education, advanced training, 
and careers. Three components form the core of STW programs: school-
based learning, work-based learning, and connecting activities. First, 
school-based learning refers to instruction and curricula that 
integrate academic and vocational learning. Second, work-based learning 
includes job training and work experiences that coordinate with 
classroom learning, workplace mentoring, and instruction in general 
workplace competencies as well as all aspects of an industry, leading 
to the awarding of a skill certificate. Third, connecting activities 
refer to the range of activities to integrate school and work and 
include matching students with employers and mentors, linking 
participants with community services, providing technical assistance to 
schools and employers, and connecting youth development strategies with 
employers’ strategies for upgrading workers’ skills. 

As the entity responsible for implementing WIA, DOL has issued guidance
and provided assistance on various technical aspects of WIA’s 
implementation. For example, through its Training and Employment 
Guidance letters, DOL has provided guidance to state and local boards on
a number of topics, including how to integrate the summer and year-round
youth programs, provide comprehensive youth services, and identify 
sources of funding for youth services. In addition, DOL has sponsored
national and regional conferences that serve as a forum to educate local
boards and youth councils on implementing WIA’s youth provisions and to
share information on promising practices. In emphasizing state and local
flexibility, DOL guidance has been very broad, and the establishment of
specific policies has been delegated to states and local areas. 

WIA’s Youth Provisions Implemented but Not without Some Challenges: 

With few exceptions, local workforce investment boards implemented
WIA’s required youth provisions by establishing youth councils and a
network of youth service providers, despite some implementation
challenges. We found that nearly all of the youth councils were active 
by the start of program year 2000—the first WIA program year—and a
majority of councils included the WIA-required members. However, a
number of the local boards reported difficulty in recruiting youth and
parents to serve on the council. To establish a network of youth service
providers, youth councils recommended service providers to their local
boards through the competitive selection process and developed 
strategies for connecting youth to the one-stop service delivery 
system, although officials in some local areas we visited described 
difficulties in doing so. Most local boards reported that their 
contracted youth service providers served youth directly rather than 
through the one-stop centers. Moreover, many boards used WIA’s 
flexibility to expand their services and move toward a comprehensive 
youth development system. These efforts included appointing optional 
representatives on the youth council such as those from private 
industry, establishing youth-exclusive one-stop centers, and securing 
additional non-WIA funding to increase their capacity to serve a 
broader group of youth, some of whom would not be WIA-eligible. 

Youth Councils Were Established, Active, and Important: 

Nationally, virtually every local workforce investment board 
established a youth council, and 78 percent had done so by July 1, 
2000, when the first WIA program year began. In fact, 72 percent of the 
boards implemented the youth council requirement in the year preceding 
July 1, 2000, in anticipation of WIA. Also, by the end of the first 
program year, nearly all youth councils had held at least one meeting 
since their inception, with the average number of meetings held being 
eight. Most youth councils (70 percent) had between 11 and 25 members, 
and the councils as a whole averaged about 20 members. (See figure 1.) 

Figure 1: Size of Youth Councils: 

[Refer to PDF for image] 

This figure is a vertical bar graph depicting the following data: 

Size of Youth Councils: 

Number of members: 5 or fewer; 
Percentage of local boards: 1%. 

Number of members: 6-10; 
Percentage of local boards: 7%. 

Number of members: 11-15; 
Percentage of local boards: 24%; 

Number of members: 16-20; 
Percentage of local boards: 27%. 

Number of members: 21-25; 
Percentage of local boards: 19%. 

Number of members: 26-30; 
Percentage of local boards: 10%. 

Number of members: 31-35; 
Percentage of local boards: 7%. 

Number of members: 36 or more; 
Percentage of local boards: 5%. 

Source: GAO’s survey of local workforce investment board directors. 

[End of figure] 

In addition, more than half of the local boards reported that most or 
all of the youth council members typically attended the youth council 
meetings, and 36 percent said that about half of the members attended. 
Finally, 56 percent of all local boards reported that their youth 
council membership included all four categories of WIA-required members 
asked about in our survey.[Footnote 15] Among the WIA-required members, 
personnel experienced in youth activities were represented on the 
greatest proportion—93 percent—of youth councils. In contrast, parents 
of WIA-eligible youth were represented on the lowest proportion (about 
71 percent) of youth councils. 

Board officials and service providers in many local areas we visited 
stated that WIA boards and youth councils were important to 
coordinating a broad array of youth services in the community and 
leveraging resources. Board officials in Sonoma County, California, for 
instance, told us that the youth council brought key stakeholders to 
the table for the first time, including representatives that had seldom 
collaborated with each other, such as those from the juvenile justice 
and school systems. Service providers in San Jose, California, and 
Cheyenne, Wyoming, stated that the youth council meetings were a good 
forum for sharing information and learning how providers could 
complement one another’s youth services to eliminate service gaps or 
duplication. In addition, board officials in Madison, Wisconsin, told 
us that the large membership size of the local board and youth council 
offered the potential to leverage additional community resources. 

Establishing youth councils, however, was not without its challenges.
Nationwide, 65 percent of local boards reported difficulty in getting 
youth members and 54 percent found it difficult to get parents of 
eligible youth to participate on the council.[Footnote 16] One local 
board official we visited told us that securing youth participation on 
the council was challenging, in part because youth lacked 
transportation to youth council meetings, found it intimidating to 
attend large meetings dominated by adults, or had class and work 
schedules that conflicted with council meetings. A state board official 
said that parents of WIA-eligible youth, often low-income themselves, 
were also difficult to recruit onto councils because they could not 
attend council meetings without taking unpaid time off from work. 

Local Boards and Youth Councils Established a Network of Youth Service
Providers: 

To establish a network of WIA youth service providers, local boards
competitively selected youth service providers based on youth council
recommendations, but some boards reported that their youth councils
found it difficult to obtain multiple responses to the requests for 
proposals (RFPs.) Nationwide, 80 percent of youth councils issued 
competitive RFPs in program year 2000, and most of those that issued 
the RFPs identified between 2 and 12 eligible service providers. About 
10 percent of the councils that issued RFPs reported that they 
identified only one eligible provider. While youth councils received 
responses to their RFPs, generally there was little competition for 
service provider contracts in many local areas. We found that 63 
percent of the councils recommended to the local board for its approval 
the same number of service providers as they had identified through the 
RFP selection process. In addition, 95 percent of local boards that 
received recommendations from their youth councils selected all of the 
recommended providers. A local board official in Milwaukee, Wisconsin, 
told us that, while the board selected the same providers that had 
served youth under JTPA, the youth council wanted to encourage new 
providers to apply for WIA service contracts, including private sector 
providers. 

Most local boards reported that contracted service providers generally
served youth directly at the providers’ facilities rather than at the 
one-stop centers in their local areas. In most of the one-stop centers 
we visited, youth were served alongside adults. In general, the centers 
featured a self-service resource room equipped with personal computers, 
phones, or other job search aids, as well as office space for one-stop 
staff and agency partners to offer a variety of employment, training, 
and social services. Employers conducted job interviews at some one-
stop centers, and officials at the rural New Jersey one-stop we visited 
told us that the state offered employers financial incentives for 
hiring one-stop clients. A few of the one-stops offered a child 
playroom or an adaptable computer workstation for disabled users, and 
in two of the centers, staff members of the various partner agencies 
were dispersed throughout the office space to promote their interaction 
and seamless service delivery. 

Most local boards at the sites we visited required contracted service
providers to make available all 10 required program elements to youth
enrolled in WIA programs. For example, one WIA provider in rural
Wisconsin delivered all 10 elements in a long-term, year-round program 
for out-of-school youth. In the program, 16- to 24-year-olds worked in 
teams to build or refurbish low-income housing. At the building sites, 
the participants received paid employment, occupational skills training,
leadership opportunities, and mentoring from an adult supervisor. When
not at the sites, they received classroom instruction to prepare for 
their high school equivalency credential, career counseling, and a 
variety of support services, such as health care, meals, and mental 
health counseling. Upon exiting the program, selected participants 
received monthly follow-up services for at least two years. 

New Service Strategies Presented Some Implementation Challenges: 

Even though most youth councils reported that they issued RFPs, one of
the challenges local areas—often rural ones—faced was in obtaining
multiple responses to their RFPs. For example, state board officials in
North Dakota said that the limited number of service providers in the
state’s sparsely populated and spread-out rural areas necessitated the 
use of the one-stop center to serve WIA youth and prompted state 
officials to seek a waiver from DOL to the competitive selection 
requirement for those local areas. Other state and local WIA officials 
in both rural and urban areas stated it was difficult to identify 
qualified service providers due to providers’ lack of experience in 
delivering WIA’s broader range of mandatory services and greater 
emphasis on serving out-of-school youth compared to JTPA. To develop 
providers’ qualifications, the local boards in Middlesex County, New 
Jersey, and Miami, Florida, conducted regular workshops to educate 
providers on their new expectations under WIA. In addition, some state 
and local WIA officials told us that some of the 10 program elements, 
such as mentoring and the 12-month follow-up, were difficult or costly 
to deliver and discouraged service providers from responding to the 
RFPs. To mitigate potential disincentives for service providers, local 
board officials in Orange Park, Florida, said that they planned to have 
one-stop staff rather than service providers conduct follow-up, which 
would also help link youth to the one-stop system, and local board 
officials in Madison, Wisconsin, told us they planned to coordinate 
some WIA follow-up services with those of non-WIA programs, such as 
Temporary Assistance for Needy Families (TANF).[Footnote 17] 

Even though one-stop centers offered WIA youth services, another
challenge faced by most local areas we visited was attracting youth to 
the one-stop centers, and these areas had developed outreach strategies 
to bring youth into the centers. Unless referred to or brought into the 
one-stop centers by schools and other service providers, youth 
typically did not come into the centers on their own.[Footnote 18] In 
some areas, such as rural Wisconsin, public transportation to the one-
stop center was not available. One service provider we interviewed was 
reluctant to send youth to the one-stop because the services were 
geared primarily toward adult clients or youth might have felt 
uncomfortable mingling with the adult clientele. Nationally, local 
boards were engaged in efforts to link youth to one-stops, and nearly 
three-quarters of boards did so by recruiting youth to the centers. 
(See figure 2.) 

Figure 2: Strategies to Attract Youth to One-Stop Centers: 

[refer to PDF for image] 

This figure is a vertical bar graph depicting the following data: 

Strategies to Attract Youth to One-Stop Centers: 

Strategy: Recruiting youth; 
Percentage of local boards that used the strategy: 73%. 

Strategy: Placing youth program staff at one-stop; 
Percentage of local boards that used the strategy: 64%. 

Strategy: Training one-stop staff in youth programs; 
Percentage of local boards that used the strategy: 48%. 

Strategy: Making facility more attractive to youth; 
Percentage of local boards that used the strategy: 35%. 

Strategy: Other; 
Percentage of local boards that used the strategy: 26%. 

Source: GAO’s survey of local workforce investment board directors. 

[End of figure] 

Local areas we visited had also developed various strategies to link 
youth to one-stop centers. For example, the one-stop center in rural 
Wisconsin we visited conducted job fairs and was authorized to hand out 
work permits—a prerequisite for younger youth to obtain employment. The
local board in Middlesex County convened focus groups with youth to
identify ideal locations for a one-stop center and youth services that
should be provided there. The one-stop center we visited in rural 
Florida was located inside a shopping mall and was considering 
advertising its services in the mall’s movie theater because it was 
frequented by youth. Recognizing one-stop systems’ adult focus, DOL 
announced in September 2001 that it had awarded competitive grants to 
15 local boards and youth councils to develop and implement strategies 
to improve youth connections to the one-stop system, which DOL plans to 
disseminate in a technical assistance guidebook after the project’s 
completion sometime this year. 

Local Boards and Youth Councils Exercised Flexibility to Promote Youth 
Development: 

Most youth councils exercised the flexibility provided by WIA by 
expanding their membership to include optional representation. For
example, 80 percent of youth councils include one or more members from
the private sector—the most frequent group (36 percent) to chair the
youth council. (See figure 3.) Other optional members included organized
labor and vocational rehabilitation representatives. Local board 
officials in Cumberland/Salem County, New Jersey, told us that having 
co-chairs from private industry helped them connect with area 
employers, leverage additional youth funding, and have greater 
knowledge of the local labor market. Board officials in several local 
areas noted, however, that getting business to fully participate on 
youth councils was still a challenge, in part because business members 
were reluctant to contribute resources or were accustomed to making 
policy decisions, not merely serving in an advisory capacity to the 
local board. 

Figure 3: Percentage of Local Boards with a Youth Council Whose Members 
or Chair(s) Represented Various Categories of WIA-Required and Optional 
Personnel: 

[Refer to PDF for image] 

This figure is a horizontal bar graph depicting the following data: 

Percentage of local boards with Personnel from youth service agencies: 
Members: 92%; 
Chair(s): 11%. 

Percentage of local boards with Personnel from public housing: 
authorities
Members: 75%; 
Chair(s): 2%. 

Percentage of local boards with Parents of WIA-eligible youth: 
Members: 71%; 
Chair(s): 2%. 

Percentage of local boards with Personnel with experience in youth 
activities: 
Members: 93%; 
Chair(s): 12%. 

Percentage of local boards with Personnel from the private sector[A]: 
Members: 80%; 
Chair(s): 36%. 

Percentage of local boards with Personnel from non-profit 
organizations[A]: 
Members: 94%; 
Chair(s): 20%. 

Percentage of local boards with Other[A,B]: 
Members: 39%; 
Chair(s): 25%. 

[A] Other categories of youth council membership or youth council chair 
included representatives from such groups as organized labor, economic 
development organizations, Native American groups, vocational 
rehabilitation agencies, and parks and recreation agencies. 

[B] Optional member. 

Source: GAO survey of local workforce investment board directors. 

[End of figure] 

A few local boards—nearly 5 percent nationally—reported having 
established one or more one-stop centers that served only youth. 
[Footnote 19] In Miami, for example, the youth one-stop centers we 
visited were either co-located with or were adjacent to the 
comprehensive one-stop centers. The one-stop operators told us that 
this arrangement gave them the flexibility of referring youth that were 
otherwise ineligible for WIA youth services to the comprehensive 
center. The youth one-stop centers were also electronically linked with 
other service providers and one-stop centers in the community. 
Milwaukee, Wisconsin, opened a new youth one-stop center in February 
2002, featuring a lounge area, recreation, childcare, as well as youth-
specialist staff cross-trained in all the one-stop partner programs and 
services in order to promote more seamless service delivery. 

Local boards also exercised their flexibility under WIA to expand their
capacity to serve both WIA and non-WIA at-risk youth by leveraging
additional resources to supplement their WIA formula grant. Nationally, 
50 percent of local boards reported having non-WIA funding available in
program year 2000 for youth activities. The extent to which non-WIA
funding supplemented WIA Title I-B youth funding varied by type of local
workforce investment area. Rural areas were less likely than nonrural
areas to receive non-WIA funds. For example, in local areas that 
described their workforce investment area as a portion of a rural area, 
non-WIA funding represented, on average, an additional $375,000 or 50 
percent of the WIA Title I-B grant, compared to an additional $941,000 
or 83 percent in nonrural areas.[Footnote 20] To supplement WIA youth 
funds, several state and local board officials told us that they were 
combining WIA with funds from TANF or other programs. For example, 
Pennsylvania used state TANF dollars to award competitive grants to 
local boards to serve both WIA and non-WIA youth. While built around 
WIA’s 10 program elements, the grants encouraged local areas to design 
innovative approaches to serving all youth but also required them to 
identify ways of sustaining the programs given that the availability of 
grant funding was uncertain. Furthermore, the youth council in Orange 
Park, Florida, encouraged the leveraging of non-WIA resources in its 
RFPs to service providers. 

Educators Participated on Youth Council and Delivered Services but
Remained Tentative Partners: 

To establish linkages with the education community, most youth councils
included local educators and STW representatives as either members or
chair of the council, even though these members were not mandated
under WIA. Moreover, secondary and postsecondary schools were 
contracted to provide youth services, typically delivering services at 
the schools, or partnered with the one-stop centers to deliver youth 
services. However, some youth councils found it difficult to partner 
with the education community due to the absence of a shared vision of 
youth development. In these communities, some school personnel were 
reluctant to incorporate workforce development activities into 
classroom learning because they did not want to broaden their role in 
youth development beyond education. Both youth council officials and 
educators expressed a need for additional technical assistance to 
strengthen linkages between the education and workforce communities. 

Educators Played an Active Role on Youth Councils: 

Nationwide, most youth councils established linkages with the education
community by including educators on their youth councils, even though
they were not mandated youth council members. For example, 94 percent
of local workforce investment boards reported that school district
personnel served on their youth council, while 79 percent reported that
STW representatives were on the youth council.[Footnote 21] In 
addition, we found school district representatives chaired 20 percent 
of the youth councils, and 13 percent were chaired by an STW 
representative. 

A majority of the local workforce investment boards we surveyed reported
it was easy to get educators to participate on the youth council. 
[Footnote 22] In some of the local areas we visited, educators who were 
members of their local STW committee easily transitioned to the WIA 
youth council. In Miami, for example, many members of the STW committee 
served as members of the youth council even though additional youth 
council members were appointed to meet WIA’s membership requirements. 
Furthermore, in Sonoma County, the youth council established linkages 
with the education community by serving as a committee to both the 
local workforce investment board and STW board. In both of these 
communities, the local boards and youth councils credited their 
partnership with STW for strengthening their relationship with the 
schools. 

Schools Were Used as Youth Service Providers and Worked with One-Stop
Centers: 

In all the sites we visited, youth councils developed various 
strategies to link with the education community including contracting 
with schools as service providers and partnering schools with the one-
stop centers to deliver youth services. (See table 3.) 

Table 3: Selected Strategies Youth Councils Developed to Link with 
Education: 

Local workforce investment board: San Jose/Silicon Valley, Calif.
School were contracted service providers: [Check]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Empty]; 
Schools incorporated workforce development activities into classroom 
learning: [Empty]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Empty]. 

Local workforce investment board: Sonoma County, Calif. 
School were contracted service providers: [Empty]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Check]; 
Schools incorporated workforce development activities into classroom 
learning: [Check]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Check]; 

Local workforce investment board: First Coast Workforce Development, 
Inc., Fla.[A]: 
School were contracted service providers: [Check]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Check]; 
Schools incorporated workforce development activities into classroom 
learning: [Check]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Check]; 

Local workforce investment board: South Florida Workforce Development 
Board, Fla.[B]: 
School were contracted service providers: [Check]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Check]; 
Schools incorporated workforce development activities into classroom 
learning: [Check]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Check]; 

Local workforce investment board: Cumberland/Salem County, N.J. 
School were contracted service providers: [Check]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Check]; 
Schools incorporated workforce development activities into classroom 
learning: [Check]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Check]; 

Local workforce investment board: Middlesex County, N.J. 
School were contracted service providers: [Check]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Check]; 
Schools incorporated workforce development activities into classroom 
learning: [Check]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Check]; 

Local workforce investment board: Private Industry Council of Milwaukee 
County, Wis. 
School were contracted service providers: [Check]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Check]; 
Schools incorporated workforce development activities into classroom 
learning: [Check]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Empty]. 

Local workforce investment board: Workforce Development Board of South 
Central Wis.[C]: 
School were contracted service providers: [Check]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Check]; 
Schools incorporated workforce development activities into classroom 
learning: [Check]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Empty]. 

Local workforce investment board: Cheyenne, Wyo.[D]: 
School were contracted service providers: [Check]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Check]; 
Schools incorporated workforce development activities into classroom 
learning: [Check]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Check]. 

Local workforce investment board: Gillette, Wyo.[D]: 
School were contracted service providers: [Check]; 
Schools delivered youth services on-site: [Check]; 
Schools partnered with one-stop centers to deliver youth services: 
[Check]; 
Schools incorporated workforce development activities into classroom 
learning: [Check]; 
Schools trained teachers on integrating workplace learning in the 
classroom: [Check]. 

Note: A "Check" indicates that one or more schools in the local area 
were employing the selected strategy. 

[A] First Coast Workforce Development, Inc., is located in Orange Park 
and serves six counties: Baker, Clay, Duval, Nassau, Putnam, and St. 
John. 

[B] South Florida Workforce Development Board is located in Miami and 
serves two counties: Miami-Dade and Monroe. 

[C] Workforce Development Board of South Central Wisconsin is located 
in Madison and serves six counties: Columbia, Dane, Dodge, Jefferson, 
Marquette, and Sauk. 

[D] Wyoming is a single workforce investment area state. One-stop 
center locations include Cheyenne and Gillette. 

[End of table] 

Most of the local workforce investment boards we visited awarded service
contracts to secondary or postsecondary schools that either provided 
youth services directly or in collaboration with other education 
providers or community-based organizations. For example, an education 
provider we visited in Cumberland/Salem County, New Jersey, 
collaborated with local school districts, universities, and private 
businesses to operate a program designed to help youth explore careers 
in the food industry. During the summer portion of the program, 30 in-
school youth between the ages of 14-16 learned basic job skills in the 
classroom, took organized field trips to farms and food businesses, and 
acquired work experience at participating local food businesses and 
restaurants. During the remainder of the school year, students were 
placed in paid internships within the food industry and received 
mentoring services from employers as well as ongoing career counseling 
from their school. In Milwaukee, the local board contracted with the 
University of Wisconsin-Milwaukee to provide a 6-week computer 
technology program for in-school youth between the ages of 15-19. On 
Saturday mornings, participants attended classes in word processing, 
slide presentation, and web page development at the college campus. 
Upon completion of the computer courses, participants were then 
enrolled in a six-week program in life skills and learned how to balance
school with work, prepare for the workforce, and manage interpersonal
working relationships on the job. 

Most of the one-stop centers we visited established linkages with the
education community by partnering with schools to provide services to
youth. For example, some local high schools brought students into the
one-stop centers to learn about available services or to participate in
career fairs. To link schools with one-stop centers, staff from the
Milwaukee youth-only one-stop traveled to high schools to conduct
computerized assessments and help them develop career plans for WIA
participants. 

Some Educators Remained Tentative Partners: 

Some educators remained cautious about increasing their involvement in 
providing WIA youth services. First, some educators believed that WIA’s 
vision for providing comprehensive youth development services to at-
risk youth was inconsistent with the traditional mission that schools 
generally embraced, which was to provide academic services to all 
youth. In Milwaukee, for example, some schools were reluctant to allow 
WIA youth services to be provided at the schools because of the 
perceived stigma associated with WIA services being targeted to low-
income, at-risk youth. In California and Florida, some educators said 
schools in their areas emphasized increasing student academic 
achievement and standardized test scores, rather than promoting 
students’ exposure to career exploration. Consequently, some educators 
were reluctant to incorporate workforce development activities into 
classroom learning, particularly where student academic achievement was 
tied to sanction and incentive policies. 

Second, some education providers we visited stated that the costs of
providing WIA youth services outweighed the benefits of education’s
participation. For example, a school official in rural Wisconsin told 
us that meeting WIA’s requirement to conduct a minimum 12-month follow-
up and reporting on participant outcomes was resource intensive for the 
school and demanded administrative time that could be better spent on 
direct service delivery. Furthermore, workforce investment officials in 
Delaware and Illinois stated that colleges were required to report 
performance data on all enrolled students, in addition to WIA students. 
According to these officials, this reporting requirement increased the 
colleges’ paperwork burden and costs relative to the amount of WIA 
funding they received, creating a financial disincentive for colleges 
to provide WIA services. 

Many local board, youth council, and education officials we interviewed
said having more formal technical assistance on how to create successful
partnerships with one another would improve the linkages that WIA has
helped to create between the workforce and education communities. For
example, youth council members in Middlesex County expressed a need
for strategies to help the council effectively communicate to the 
education community that schools could play an important role preparing 
youth for the workforce. In addition, some workforce and education 
officials we visited expressed a need for examples of promising 
practices used by others to strengthen the links between the one-stop 
centers and schools. 

State and Local Factors Facilitated Implementation, but Some New
Requirements Inhibited Service Delivery: 

Two factors facilitated implementation of WIA’s youth provisions, while
some WIA requirements impeded implementation or service delivery.
Experience in collaboration among youth-serving agencies and a high
priority placed on youth development activities by state officials 
facilitated implementation. Workforce officials told us that these 
factors enabled them to work more cooperatively and with a wider range 
of community providers in coordinating and delivering youth services. 
However, workforce officials also stated that implementation progress 
and service delivery were inhibited by requirements to document 
eligibility and to spend 30 percent of WIA youth funds on out-of-school 
youth services and by unclear youth performance indicators. 

Implementation Facilitated by Historical Collaboration and Priority on 
Youth: 

Two factors enabled state and local workforce officials to work 
collaboratively with representatives and improve coordination and 
delivery of youth services—experience in collaboration and priority
placed on youth development. Many state workforce officials we 
interviewed were already experienced in collaborating with state and 
local agencies, local boards, and youth-serving organizations. In New 
Jersey, for example, state officials told us that WIA’s requirements to 
establish partnerships did not represent a significant shift because 
many state and local youth-serving agencies were already working 
together to share information and provide services. Officials in most 
of the local areas we visited characterized the collaboration among the 
service providers, local board and youth council, and youth-serving 
agencies as strong due primarily to their longstanding relationships. 
Likewise, some organizational structures facilitated WIA implementation 
by encouraging collaboration. A number of state officials we 
interviewed told us they consolidated some state workforce, education, 
or human service functions prior to WIA’s implementation in order to 
streamline and improve coordination and delivery of youth services. For 
example, Michigan began consolidating its state workforce development 
programs in the early 1990s. A single department now administers WIA as 
well as a variety of other workforce and education programs such as 
TANF, Welfare-to-Work, Wagner-Peyser employment services, vocational 
rehabilitation, secondary and postsecondary career and technical 
education, and adult education. According to state WIA officials, this 
consolidated structure helped them to sidestep potential turf struggles 
and maximize service resources available to help many populations, 
including youth, by coordinating diverse programs. 

Second, we found the high priority placed on youth development 
activities also facilitated implementation. For instance, 15 states had 
established state-level youth councils, in part, to assist local boards 
in implementing the youth provisions.[Footnote 23] In Colorado and 
Illinois, state youth council members mentored local youth council 
members, provided technical assistance, and helped local youth councils 
leverage resources. In addition, we found that 34 states had allocated 
a portion of the Governor’s 15 percent set-aside to WIA youth 
activities in program year 2000.[Footnote 24] In California, for 
example, the state used part of its 15 percent set-aside on a youth 
development and crime prevention initiative that offers alcohol and 
drug treatment, mental health counseling, job training and employment 
opportunities, and mentoring to at-risk youth. Oregon state board 
officials told us they spent some of their youth set-aside to help 
service providers deliver mentoring, summer employment, and follow-up 
youth services. 

Some WIA Provisions Difficult to Implement and Impeded Service 
Delivery: 

While WIA encouraged state and local areas to implement new approaches, 
it also included some requirements that made implementation difficult 
and impeded service delivery. State and local board officials were 
concerned with collecting documentation needed to verify eligibility for
WIA youth services, spending at least 30 percent of WIA youth funds on
out-of-school youth, understanding and measuring youth performance
indicators, and meeting partnering requirements. The challenge of 
meeting these requirements often hindered implementation, excluded 
potentially eligible youth from participating in WIA services, and 
diverted resources away from direct service delivery, according to 
local officials. 

Documenting Income Eligibility: 

A majority of state and local officials we interviewed or visited told 
us that documenting low-income eligibility was difficult to accomplish 
and resource-intensive. The law specifies that youth must be low-income 
and face one or more barriers to employment to be eligible for WIA youth
services. (For more information on the barriers, see app. I.) State and 
local officials told us that many at-risk youth were unable or 
unwilling to provide pertinent documentation of their income 
eligibility, such as their parents’ paycheck stub or tax return. In 
Orange Park, local board officials stated that obtaining documentation 
from at-risk youth was difficult, particularly for youth being raised 
by a single parent or grandparents or homeless youth. Service providers 
in Middlesex County, New Jersey, said that at-risk youth did not 
necessarily have a good relationship with their parents, compounding 
the difficulty of obtaining documentation. They added that getting 
documentation was also difficult in cases in which parents mistrusted 
service providers whom they perceived as prying into their financial 
affairs. Consequently, the most at-risk youth were the least likely to 
be able to provide documentation to verify their eligibility for needed 
services, according to local board officials. 

In addition, local board officials said obtaining necessary 
documentation was time consuming and diverted financial and staff 
resources away from direct service delivery. One local board in Florida 
terminated a youth program because of the high administrative costs of 
documenting eligibility. Officials at this local board estimated that, 
with the change in eligibility requirements from JTPA, the number of 
documents increased from 1 to 21 and the processing time increased from 
less than 2 hours to between 10 and 20 hours per participant. These 
additional hours could have been better spent in delivering services 
rather than processing paperwork, according to the officials. Some 
state and local board officials told us that they preferred using the 
free-and-reduced-school-lunch program’s income criterion under JTPA 
because it was more efficient and cost effective to use existing 
documentation, usually a single list compiled by the schools. 

Some states, however, had developed strategies for addressing the
concern over documentation. California, Pennsylvania, and Texas, for
example, developed technical assistance guides listing procedures for
documenting and verifying participant eligibility. To document that a
youth met the deficient-in-basic-literary-skills eligibility 
requirement, for instance, the Texas guide identified acceptable forms 
of documentation, which included results of a generally accepted 
standardized test, school records, and verification by telephone. DOL 
is in the process of finalizing guidance concerning eligibility 
documentation and projects that policy guidance will be issued later 
this year. 

Meeting Spending Requirement for Out-of-School Youth: 

WIA requires 30 percent of local WIA youth funds be spent on out-of-
school youth, but many local officials said that recruiting and 
retaining sufficient numbers of these youth was challenging for a 
variety of reasons and hindered implementation efforts. For example, in 
Madison, Wisconsin, and Cumberland/Salem County, New Jersey, officials 
said it was more difficult to locate and follow-up on this “hidden 
population” in contrast to in-school youth, who could be tracked 
through the education system. Additionally, DOL officials told us that 
many out-of-school youth get employment, which may make them ineligible 
for WIA programs because their income is too high. Finally, WIA 
officials in one local area told us that it was difficult to retain out-
of-school youth in WIA programs because they were typically more 
motivated to get a job than to acquire the academic skills needed to 
prepare them for further education or careers. 

Some local areas had developed innovative ways of recruiting and
retaining out-of-school youth. In Miami and Milwaukee, for example, the
local boards established youth-only one-stop centers so that out-of-
school youth could come into a youth-friendly facility. In addition, 
local officials in Miami told us that youth caseworkers went to malls 
and other areas frequented by out-of-school youth to recruit program 
participants. Service providers in Cheyenne described a youth-friendly 
facility, which served youth who were already in or were transitioning 
from foster care or who had been in an out-of-home placement. The 
facility also provided a job preparation program for WIA participants. 
Milwaukee board officials told us they planned to staff their new youth-
only one-stop center with out-of-school youth specialists. Finally, a 
service provider in rural Wisconsin collaborated with the juvenile 
justice and school systems to help recruit out-of-school youth. DOL 
plans to issue guidance on recruiting and retaining out-of-school youth 
in April 2002. 

Measuring Performance Indicators and Setting Performance Goals: 

Another challenging WIA requirement identified by state and local 
officials was measuring youth performance indicators and setting 
performance goals. State and local WIA officials reported difficulties 
in measuring some of the performance indicators because of ambiguous 
definitions and problems with data availability.[Footnote 25] For 
example, Illinois state board officials said that unclear definitions 
of the credential and skill attainment indicators could lead to 
inconsistent reporting of outcomes among states. While DOL officials 
told us they developed the definition of some youth indicators in 
collaboration with the Department of Education, they added that some 
measures were defined very broadly to give states flexibility in 
implementing performance accountability systems. For example, DOL 
allows state and local areas to determine what constitutes a credential 
and to develop—with employer input—-a statewide list of approved 
credentials. DOL officials acknowledged that some states defined 
credentialing and skill attainment more broadly than others. 
Additionally, several WIA officials said that, because some of the 
measures are based on Unemployment Insurance wage records, there was 
typically a 6-9 month lag before the data were available, making it 
difficult for boards to use the indicators to plan strategically or 
evaluate service provider performance. According to state and local 
officials, ambiguous definitions and lags in data availability 
complicated the measurement and reporting of some WIA youth performance 
indicators and resulted in inconsistencies in reporting and comparing 
outcomes within and across states. 

Furthermore, state and local officials reported that the youth 
performance goals were set at unrealistic levels—usually too 
high—because they were established without input from state and local 
officials and were derived from unreliable baseline data. Officials in 
several state and local areas we visited or contacted said they had 
little or no input into their performance goals during the negotiation 
process. DOL officials acknowledged that input was limited because some 
youth measures were new under WIA or new to DOL, and the agency lacked 
adequate time to negotiate goals from the local level up to the state 
level as it had intended. In addition, performance goals reflected 
baseline data from JTPA and the experience of a limited number of early 
implementation states. Also, some state officials we interviewed 
reported that the performance goals did not take into account states’ 
individual circumstances. DOL issued guidance in February 2002 on 
renegotiating performance levels. In the guidance, DOL noted that 
limitations in JTPA baseline data used to project performance levels 
for program years 2001 and 2002 satisfied one of the conditions for
requesting revisions to earlier negotiated performance levels. 
[Footnote 26] 

Meeting the Partnering Requirements: 

WIA requires state and local workforce boards and youth councils to
collaborate with a host of other partners such as public youth-service
agencies, labor organizations, and community-based organizations. The
law envisions these entities becoming board and council members, one-
stop partners and operators, and service providers. While we found that
many of these agencies did indeed participate on youth councils and
deliver WIA services, state and local WIA officials said that 
collaborating among the different agencies was difficult and 
frustrating, and they lacked strategies to effectively partner with 
these agencies. For example, officials from one local board we visited 
told us that they were having difficulty finding other agencies to 
partner with in their efforts to implement WIA. These officials said 
that, while some agencies were active partners on the youth council, in 
the one-stop center, or as service providers, they believed the 
legislation did not make it easy to collaborate because it did not 
require other agencies to contribute resources nor did it provide local
areas with the tools to enforce collaboration. Officials from another 
local board said that different administrative rules, definitions, and 
reauthorization timeframes among programs administered by the different
federal agencies undermined the collaboration with which local workforce
investment boards are charged. Yet we found some state and local
initiatives that attempted to address these concerns and facilitate 
greater collaboration. A state WIA official in New York, for example, 
told us that the state workforce board was finalizing its plan to blend 
the performance measures for WIA and several non-WIA programs to promote
collaboration and consistency. 

Conclusions: 

WIA aims to significantly reconfigure the way services for at-risk 
youth are structured and delivered. With its mandated requirements to 
form youth councils reflecting broad community representation, WIA 
presents a unique opportunity to make fundamental changes in the way 
youth services are provided—but implementation challenges remain.
Establishing new governance structures, building and sustaining diverse
new partnerships, designing comprehensive, coordinated programs, and
delivering services seamlessly will take considerable effort from state 
and local workforce boards and their youth councils. State and local 
areas must meet implementation challenges such as getting youth, 
parents, and businesses to participate on youth councils, promoting 
competition in the service provider selection process, and serving new 
and difficult populations. The new performance measurement system under 
WIA also poses challenges for states and local areas that are concerned 
that ambiguous definitions of skill attainment, for example, and use of
unreliable baseline data to set performance goals would result in
inconsistencies in reporting and comparing outcomes. Although states and
local boards welcome the enhanced flexibility WIA affords them, many are
only now acclimating to their new roles and relationships in the 
workforce development system. However, the lack of information and 
technical support on a number of these new responsibilities has 
hindered state and local boards in fully realizing WIA’s potential. If 
progress is to continue, state and local workforce investment boards 
and their youth councils will need additional help in building a 
comprehensive youth development system. 

State and local workforce board officials, youth council members, and
youth service providers have—for the most part—embraced both WIA’s
broad workforce development vision and the specifics of the youth
provisions. Given the scope of youth program reforms legislated in WIA
and the extent of implementation to date, significant progress has been
made. Federal agencies, however, need to continue to monitor progress
and assess state and local needs for additional support and guidance to 
further facilitate implementation. The building of a comprehensive youth
development system as envisioned by WIA requires active and sustained
leadership—especially at the national level—and strong working
relationships between the workforce development and education systems
at all levels of government. While forging strong linkages between these
two systems is critical in preparing youth not only for success in the
classroom but also for their future careers, some local educators remain
hesitant to participate in WIA youth programs. Workforce and education
officials acknowledge the need for more assistance to help strengthen 
the partnership between these two systems. 

Recommendations for Executive Action: 

To improve the availability of information on WIA youth programmatic,
administrative, and other implementation issues and to enhance
implementation of state and local workforce investment systems, we
recommend that the Secretary of Labor issue guidance and provide
assistance to state and local boards and youth councils by developing 
and disseminating strategies: 

* to effectively recruit and engage parents, youth, and business 
community representatives on the youth council; 

* to increase the number of responses to competitive requests for 
proposals by encouraging youth-serving organizations new to WIA to 
participate in the youth program and promoting new ways of 
collaboration among new and existing service providers; 

* to obtain and verify applicant eligibility information by sharing 
client information among agencies or using existing electronic 
databases (for example, DOL should consider exploring methods to extend 
eligibility automatically for WIA based on an applicant’s participation 
in other programs);[Footnote 27] 

* to recruit and retain out-of-school youth to the WIA youth program 
and all youth into the one-stops; and: 

* to facilitate linkages between the board and youth council and their
required youth-serving partners. 

Through collaboration with the Department of Education, state education
agencies, and other experts, we recommend the Secretary of Labor
develop and disseminate strategies: 

* to effectively link workforce and education activities, such as 
exploring workplace learning principles in the classroom and connecting 
schools to the one-stop centers. 

To more objectively assess state and local area performance and youth
progress, we recommend that the Secretary of Labor: 

* clarify the definition of skill attainment for younger youth to ensure
consistency in reporting.[Footnote 28] 

Agency Comments and Our Evaluation: 

We provided a draft of this report to DOL for its review and comment. 
DOL’s comments are in appendix II. In its written comments, DOL agreed
with all our findings and recommendations, noting that they are 
consistent with information it has collected from state and local 
implementers. DOL also found the report to be instructive in assessing 
local implementation efforts nationwide and highlighting best practices 
to improve youth services. In its comments, DOL cited its efforts to 
work closely with state and local partners to provide guidance and best 
practices on the issues identified in our recommendations, including 
issuing a tool kit on effective youth councils, reaching out to 
community-based and faith-based organizations for competitive selection 
of providers, simplifying eligibility documentation procedures, 
developing a best practices website on serving out-of-school youth, 
integrating school-to-work lessons learned, and clarifying the 
definition of skill attainment. 

As arranged with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 5 days 
after the date of this report. At that time, we will send copies to the 
Secretary of Labor, relevant congressional committees, and others who 
are interested. Copies will be made available to others upon request. 
The report is also available on GAO’s home page at [hyperlink, 
http://www.gao.gov]. 

Please contact me on (202) 512-7215 if you or your staff have any
questions about this report. Other major contributors to this report are
listed in appendix III. 

Signed by: 

Sigurd R. Nilsen: 
Director, Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Comparison of Key Youth Provisions under WIA and JTPA: 

Youth provision: Funding; 
WIA: 
* Single funding stream that integrates summer and year-round programs; 
* 15 percent set aside for statewide activities, 85 percent allocated 
to local areas. 
JTPA: 
* Summer Youth Employment and Training (Title IIB), 100 percent 
allocated to local areas; 
* Youth Training Program (Title II-C) for year-round services, 18 
percent set aside for statewide activities, 82 percent allocated to 
local areas. 

Youth provision: Target population; 
WIA: 
* In-school youth; 
* Out-of-school youth. 
JTPA: 
* In-school youth; 
* Out-of-school youth. 

Youth provision: Eligibility; 
WIA: 
* Age 14-21, youth that are 18-21 years old may be considered adults 
and may be concurrently enrolled in WIA adult and dislocated worker 
programs; 
* Low-income and faces one or more barriers: (1) deficient in basic 
skills, (2) school dropout, (3) homeless, runaway, or foster child, (4) 
pregnant or parent, (5) offender, (6) requires additional assistance to 
complete an education program or to secure and hold employment; 
* At least 30 percent of youth funding must be spent on out-of-school 
youth; 
* Five percent of youth may be non-low income but must face one or more 
barriers. 
JTPA: 
* Age 16-21, in certain cases, age 14 and 15; 
* Economically disadvantaged or eligible for free school lunch during 
most recent school year; 
* For year-round program, at least 65 percent of participants must be 
youth who face barriers similar to those under WIA; no such requirement
for summer program; 
* For year-round program, at least 50 percent of participants must be 
out-of-school youth; no such requirement for summer program; 
* Ten percent of youth may be non-low income but must face one or more 
barriers similar to those under WIA. 

Youth provision: One-stop service delivery; 
WIA: 
* Each entity carrying out WIA youth programs and activities is a 
required one-stop partner and must make available their services 
through the one-stop system. 
JTPA: 
* Not applicable. 

Youth provision: Youth services; 
WIA: 
* Required: assessment, individual service strategy, preparation for 
post-secondary education or employment, strong linkages between 
academic and occupational learning, preparation for unsubsidized 
employment, connections to intermediaries with links to local labor 
market, information, and referral; 
* All 10 program elements must be made available to youth: (1) 
tutoring, study skills training, instruction leading to completion of 
secondary school, including dropout-prevention strategies (2) 
alternative secondary school services, (3) summer employment linked to 
academic and occupational learning, (4) paid and unpaid work experience 
including internships and job shadowing, (5) occupational skills 
training, (6) leadership development which may include community 
service and peer-centered activities encouraging responsibility, (7) 
supportive services, (8) adult mentoring during program participation 
and at least 12 months subsequently, 9) at least a 12-month follow-up 
upon program completion, and 10) guidance and counseling including drug 
and alcohol abuse counseling and referral. 
JTPA: 
Year-round services: 
* Required: assessment, individual service strategy, training in basic, 
occupational, and work maturity skills, work experience, and supportive 
services, information, and referral; 
* Optional program elements include: (1) tutoring, (2) alternative high 
school, (3) instruction leading to high school completion or 
equivalent, (4) mentoring, (5) limited internships, (6) training or
education combined with community and youth service, (7) entry 
employment experience, (8) school-to-work services, (9) school-to-
postsecondary education services, (10) school-to-apprenticeship
services, (11) counseling and referral, (12) services encouraging 
parental and other significant adult involvement, and (13) cash 
incentives and bonuses based on program attendance and performance; 
Summer services: 
* Required services include: assessment, individual service strategy, 
basic and remedial education, work experience, occupational training, 
job referral and placement, supportive services, follow-up services as 
appropriate. 

Youth provision: Youth service providers; 
WIA: 
* Required to be competitively selected by local board based on youth 
council recommendation. 
JTPA: 
* May be competitively selected. 

Youth provision: Governance; 
WIA: 
* State workforce investment boards; 
* Local workforce investment boards cannot be direct service providers 
unless waived; 
* Youth councils as subgroup of local board; 
JTPA: 
* State job training coordinating council or human resources investment 
council; 
* Local private industry councils. 

Youth provision: Performance indicators; 
WIA: 
* Older youth (ages 19-21) indicators include entry, retention, and 
earnings in unsubsidized employment and recognized credential 
attainment; 
* Younger youth (ages 14-18) indicators include basic skills 
attainment, attainment of secondary school diplomas and their recognized
equivalents, placement and retention in postsecondary education, 
advanced training, or employment; 
* Customer satisfaction indicators. 
JTPA: 
* Year-round program indicators include attainment of employment 
competencies, dropout prevention and recovery, secondary and 
postsecondary school completion or equivalent, and enrollment in other 
education and training programs; 
* None established for summer program. 

Source: Workforce Investment Act and its implementing regulations and 
Job Training Partnership Act. 

[End of table] 

[End of section] 

Appendix II: Comments from the Department of Labor: 

U.S. Department of Labor: 
Assistant Secretary for Employment and Training: 
Washington, D.C. 20210: 

March 22, 2002: 

Mr. Sigurd R. Nilsen: 
Director, Education, Workforce, And Income Security Issues: 
United States General Accounting Office: 
Washington, DC 20548: 

Dear Mr. Nilsen: 

On behalf of the Secretary of Labor, thank you for the opportunity to 
review the draft of your proposed report "Workforce Investment Act: 
Youth Provisions Promote New Service Strategies but Additional Guidance 
Would Enhance Program Development" (GAO-02-413). 

We appreciate the work of the General Accounting Office (GAO) on this 
report and the acknowledgement of the progress made to date by the 
state and local workforce investment system in meeting the challenges 
of creating a comprehensive youth development system, as defined in the 
Workforce Investment Act (WIA). We find the report to be instructive 
for two main reasons: (1) it provides an assessment of efforts 
undertaken by the local workforce boards nationwide; and (2) it 
highlights best practices and identifies common issues faced by 
Workforce Investment Boards and Youth Councils in improving services to 
youth. 

We agree with the report's six Recommendations for Executive Action. 
The findings and recommendations cited in the report substantiate the 
issues and concerns that we also have identified from working closely 
with state and local stakeholders. This letter elaborates on the steps 
that we are taking to address the issues identified in the report. Our 
response to each specific recommendation is articulated below. The 
report also cites three areas in which legislative requirements have 
impeded implementation progress or adversely affected service delivery. 
These issue areas are: (1) eligibility documentation and the concern 
that eligible at-risk youth may be excluded from receiving WIA 
services; (2) recruiting and retaining sufficient numbers of out-of-
school youth; and (3) ambiguous definitions and lags in data 
availability which may complicate the measurement and reporting of some 
WIA youth performance indicators. We are also currently addressing 
these issues and have incorporated our current or planned activities in 
our responses below. We have already begun a process to obtain broad 
input on issues and recommendations for changes to WIA. 

Recommendation #1: 

Effectively recruit and engage parents, youth and business 
representatives on the youth council. 

DOL's Response: 

We agree that additional assistance should be provided on best 
practices for engaging parents, youth, and business on youth councils. 
We have developed and will soon release a youth council toolkit. This 
resource guide, developed in conjunction with our state and local 
partners, contains several modules of activities for developing 
effective youth councils. One module addresses the advantages of 
broadening the membership of the council to include employers and 
educators while another module addresses strategies for recruiting and 
engaging parents and youth. We are also supporting an initiative in 
2002/2003 to showcase effective program practices through organized 
study tours to selected local areas. This project provides an 
opportunity for state and local officials to study effective Youth 
Councils and promising programs, such as quality Job Corps programs and 
high performing Youth Opportunity Grants. We will also utilize our 
Promising & Effective Practices Network (PEPNet) to identify these and 
other promising programs. This project will address best practices for 
engaging parents, youth, and business. 

Recommendation #2: 

Increase the number of responses to competitive requests for proposals. 

DOL's Response: 

This has proven to be a particularly difficult issue during the early 
years of WIA implementation. We have issued guidance to the Governors 
indicating that they may increase state and local flexibility in 
implementing WIA programs by requesting waivers of WIA requirements. We 
also issued Training and Guidance Letter (TEGL) Number 12-01 on 
February 21, 2002, addressing selected issues identified by the Youth 
Service WIA Readiness Reviews. This guidance includes additional 
clarification on the requirements for competitive selection of youth 
service providers. In addition, a program emphasis TEGL that we plan to 
issue in April includes a section on outreach to community-based and 
faith-based organizations. We believe that more effective outreach by 
local areas will increase the number of qualified applicants. 
Currently, we are considering several requests for waivers of the youth 
competitive selection requirements. We will also consider developing 
further policy clarification and developing technical assistance 
strategies for increasing the number of responses to competitive 
requests for proposals. 

Recommendation #3: 

Obtain and verify applicant eligibility information by sharing client 
information among agencies or using existing electronic databases. 

DOL's Response: 

We addressed selected issues identified by the Youth Service WIA 
Readiness Reviews in the above referenced TEGL. This TEGL includes 
clarification on documentation and verification of youth eligibility 
under WIA. We encourage states to develop their own policies and 
guidelines regarding eligibility. The TEGL suggests that one option to 
streamline registration is to allow for self-certification to verify 
those eligibility items that in some cases are not verifiable or may 
cause undue hardship for individuals to obtain. The TEGL notes that 
when self-certification is allowed, it is also important to incorporate 
a random sampling methodology to determine the accuracy of the self-
certification method for determining WIA eligibility. We are currently 
exploring a sampling methodology that could be applied across the WIA 
adult, dislocated worker, and youth programs. Upon completion, this 
sampling method would not be required but could provide an effective 
approach for reducing the burden of requiring 100 percent eligibility 
documentation for every individual registered for WIA services, while 
still ensuring a high level of confidence that youth served with WIA 
funds are indeed eligible for the program. 

The Youth and Adult program offices, with input from the Office of 
Inspector General, are also collaborating in developing guidance and 
technical assistance to simplify eligibility documentation procedures. 
One of the policy areas under consideration with particular relevance 
to recommendation #3 is presumptive eligibility, whereby eligibility in 
another program with similar low-income requirements will be extended 
to WIA programs. We project that policy guidance will be issued later 
this year. 

Recommendation #4: 

Recruit and retain out-of-school youth to the WIA youth program and all 
youth into the one-stops and facilitate linkages between the board and 
youth council and their required youth serving partners. 

DOL's Response: 

We believe that recruiting and retaining out-of-school youth (OSY) must 
continue as a priority for states and local areas, and we will 
reiterate this in a program emphasis guidance notice to be issued in 
April. This issuance includes strategies for enhancing recruitment and 
retention of OSY. For example, the Youth Opportunity Grants (YOG) have 
developed some promising practices for recruiting, serving, and 
retaining OSY. The program guidance advisory notice reviews approaches 
that YOG sites are taking to offer youth a package of education, 
employment, and recreation activities that are more appealing than 
stand-alone GED classes or job training. 

As the GAO report notes, we awarded competitive grants to 15 local 
boards and youth councils to develop and implement strategies to 
improve youth connections to the one-stop system. Interim reports from 
these one-stop Planning Grantees describe strategies being implemented 
to connect youth, including OSY, to the One-Stop system. Strategies 
that focus on OSY include: developing Youth One-Stop Career Centers 
specifically designed to engage OSY youth; marketing and outreach; 
using technology to enhance connection with schools and satellites; 
operations and staffing to support youth; enhanced facilities and self-
help services; and conducting OSY youth-only forums and focus groups. 
In February 2002, we retained Westat to develop a technical assistance 
guide (TAG) that emphasizes the successful OSP-related youth services 
implementation strategies of nine One-Stop Centers. A second part of 
the TAG will provide an overview of successful planning activities 
identified from the 15 grants to local boards and youth councils. 

We also provided funds to the Youth Development and Research Fund 
(YDRF) for a project entitled Youth Cultural Competence (YCC) - an 
innovative approach to improving recruitment, retention, and active 
engagement of youth in employment and training programs. YDRF has 
produced a manual that outlines the YCC criteria for use by WIA youth 
programs and highlights 15 programs that have incorporated the YCC 
approach in effectively serving youth in their communities. 

A promising practices website is being developed under a contract with 
the State of Illinois. The planned Internet website will be a vehicle 
for providing technical assistance on promising practices for serving 
OSY. 

Recommendation #5: 

Develop and disseminate strategies to effectively link workforce and 
education activities. 

DOL Response: 

We support the report's recommendation that we collaborate with the 
Department of Education, state education agencies, and other experts to 
develop and disseminate strategies for linking workforce and education 
activities. We reinforced the importance of this collaboration in a 
Memorandum of Understanding between the Departments of Education and 
Labor signed on June 21, 2001. This initiative focuses on: (1) 
improving current workforce basic skills (i.e., reading and math) of 
adult workers; (2) increasing Job Corps students' attainment of high 
school diplomas; and (3) providing technical assistance to state and 
local education agencies, Workforce Investment Boards, One-Stop Career 
Centers, Adult Education and Literacy grantees, and other appropriate 
entities. 

We are currently assessing other technical assistance options and 
opportunities for guidance that will be effective and appropriate 
vehicles to carry out the report's recommendation. A January 4, 2002 
joint Education and Labor letter sent to School-to-Work Opportunities 
Act grantees noted that steps have been taken to integrate the lessons 
learned from this seven-year effort into the respective Departments. We 
are now embarking on new initiatives to support the Administration's 
strategic plans for education and workforce development focused on 
ensuring academic excellence for the nation's students and promoting 
the quality and competitiveness of our 21" century workforce. We look 
forward to sharing additional information on these initiatives as they 
are developed. 

Recommendation #6: 

Clarify the definition of skill attainment for younger youth to ensure 
consistency in reporting. 

DOL's Response: 

We agree that there is a need to issue further guidance on the skill 
attainment rate to enhance comparability across states and localities. 
This will be done within the context of maintaining the flexibility 
that is the spirit of WIA and recognizing that inherent in the skill 
attainment measure is setting individual skill attainment goals based 
on individual needs. This guidance will be incorporated into the 
guidance that we will issue in response to the GAO report "Improvements 
Needed in WIA Performance Measures." 

Thank you for the opportunity to participate in this important report 
on how to better serve America's youth. 

Sincerely, 

Signed by: 

Emily Stover DeRocco: 

[End of section] 

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

David Bellis, Assistant Director (415) 904-2272: 
Meeta Sharma, Analyst-in-Charge (206) 287-4806: 

Staff Acknowledgments: 

In addition to the individuals mentioned above, Karyn Angulo, Bill 
Bates, Jessica Botsford, Patrick DiBattista, Julian Fogle, Joel 
Grossman, Jeff Rueckhaus, Rebecca Woiwode, James Wright, and Michelle 
Zapata made key contributions to this report. 

[End of section] 

Related GAO Products: 

Workforce Investment Act: Coordination between TANF Programs and One-
Stop Centers Is Increasing, but Challenges Remain. 
[hyperlink, http://www.gao.gov/products/GAO-02-500T]. Washington, D.C.: 
March 12, 2002. 

Workforce Investment Act: Better Guidance and Revised Funding Formula 
Would Enhance Dislocated Worker Program. 
[hyperlink, http://www.gao.gov/products/GAO-02-274]. Washington, D.C.: 
February 11, 2002. 

Workforce Investment Act: Improvements Needed in Performance Measures 
to Provide a More Accurate Picture of WIA’s Effectiveness. 
[hyperlink, http://www.gao.gov/products/GAO-02-275]. Washington, D.C.: 
February 1, 2002. 

Means-Tested Programs: Determining Financial Eligibility Is Cumbersome 
and Can Be Simplified. 
[hyperlink, http://www.gao.gov/products/GAO-02-58]. Washington, D.C.: 
November 2, 2001. 

Workforce Investment Act: New Requirements Create Need for More 
Guidance. GAO-02-94T. Washington, D.C.: October 4, 2001. 

Workforce Investment Act: Better Guidance Needed to Address Concerns 
Over New Requirements. 
[hyperlink, http://www.gao.gov/products/GAO-02-72]. Washington, D.C.: 
October 4, 2001. 

[End of section] 

Footnotes: 

[1] P.L. 105-220. 

[2] Although most of these services are not targeted toward youth in 
particular, youth may be receiving some services to the extent that 
they are included in the target population of individuals served by the 
federal employment and training programs. 

[3] For more information on WIA implementation, see our prior report, 
U.S. General Accounting Office, Workforce Investment Act: Better 
Guidance Needed to Address Concerns Over New Requirements, 
[hyperlink, http://www.gao.gov/products/GAO-02-72] (Washington, D.C.: 
Oct. 4, 2001). 

[4] Youth development emphasizes meeting a young person’s needs and 
building competencies for adulthood. In general, a youth development 
approach focuses on a young person’s strengths, communicates high 
expectations, provides leadership opportunities, encourages a sense of 
personal identity, broadens a young person’s perspective, provides
safe surroundings, and connects youth with caring adults. Follow-up 
over time is a crucial youth development principle to support and guide 
youth through the challenges of entering and succeeding in employment. 
John J. Heldrich Center for Workforce Development, Recipes for Success, 
Youth Council Guide for Creating a Youth Development System Under WIA, 
prepared for the Department of Labor, May 2000, and Department of Labor,
Training and Employment Guidance Letter No. 9-00 (Washington, D.C., 
2001). 

[5] We administered the survey to local workforce investment board 
directors in the 50 United States, the District of Columbia, and U.S. 
territories. 

[6] Wyoming is a single workforce investment area state; thus, we 
visited the state workforce investment board that also served as the 
local board. 

[7] Education expenditures are those for the day-to-day operation of 
schools and include expenditures for instruction, support services, and 
noninstruction. They exclude expenditures associated with repaying 
debt, capital outlays, programs outside the scope of preschool to grade 
12, and items lasting more than 1 year. 

[8] DOL’s Training and Employment Guidance Letter No. 3-99, dated 
January 31, 2000, states that JTPA funds became WIA funds on July 1, 
2000 when JTPA was officially repealed. WIA program year 2000 began on 
July 1, 2000, and ended on June 30, 2001. 

[9] Issues concerning dislocated workers are discussed in a prior 
report, U.S. General Accounting Office, Workforce Investment Act: 
Better Guidance and Revised Funding Formula Would Enhance Dislocated 
Worker Program, [hyperlink, http://www.gao.gov/products/GAO-02-274] 
(Washington, D.C.: Feb. 11, 2002). 

[10] For each fiscal year in which the appropriation for youth 
activities exceeds $1 billion, up to $250 million can be used for Youth 
Opportunity Grants. These grants are awarded to qualifying communities 
to establish youth opportunity centers where youth living in high-
poverty neighborhoods can access a wide range of services. In program 
year 2000, DOL awarded grants to 36 service areas located in urban, 
rural, and Native American sites. 

[11] Younger youth are between the ages of 14–18 and older youth are 
between the ages of 19–21. 

[12] The governor of any state that was a single-service delivery area 
under JTPA as of July 1, 1998, may designate the state as a single 
local workforce investment area state. In such cases, the state and 
local workforce investment boards are the same entity. Single workforce 
investment areas are the states of Delaware, North Dakota, New 
Hampshire, South Dakota, Utah, Vermont, Wyoming, and the District of 
Columbia. 

[13] Under certain circumstances, WIA authorizes the designation of an 
alternate entity that performs the functions of a local board or youth 
council. 

[14] Under the School-to-Work Opportunities Act of 1994 (P.L. 103-239), 
STW implementation grants were awarded to all states to fund state and 
local public-private partnerships among schools, businesses, labor 
organizations, community-based organizations, parents, and students. 
The National School-to-Work Office was jointly administered by the 
Departments of Labor and Education until the program’s termination in 
October 2001. In response, some states enacted their own STW 
legislation or policies while others realigned resources to support 
local STW partnerships. Under WIA, however, states cannot use WIA youth 
funds to finance STW activities unless the STW participant is also a 
WIA-eligible youth. 

[15] Our analysis of youth council membership excluded two of the six 
categories of required members: representatives from the Job Corps and 
representatives from the local board with experience in youth 
activities. We excluded Job Corps because not all local workforce 
investment areas have a Job Corps program. We excluded representatives 
from the local board with interest or expertise in youth policy because 
such members of the local board are also required members of the youth 
council. 

[16] To compute the percentages, we combined two of the six response 
categories, “Difficult” and “Very Difficult,” in the appropriate 
questionnaire items, and we eliminated from the analysis any local 
boards that reported they had “Not Yet Completed [the] Task” of getting
youths or parents of eligible youths to participate on the youth 
council. 

[17] TANF was created by the Personal Responsibility and Work 
Opportunity Reconciliation Act enacted in 1996 and replaced Aid to 
Families With Dependent Children, a program that provided families with 
cash assistance for an indefinite period. Administered by the 
Department of Health and Human Services, TANF is a block grant to 
states designed to promote work over welfare. In general, able-bodied 
TANF recipients who receive cash assistance must participate in work or 
work-related activities after receiving assistance for a maximum of 24 
months, and there is a 5-year lifetime limit on federal assistance. 
Work-related activities include education and training, job search, and 
community service. 

[18] Two local boards told us that some older or out-of-school WIA-
eligible youth are linked to the one-stop centers through their 
participation in non-WIA services, such as TANF, which are sometimes 
also delivered at the one-stop centers. 

[19] We visited youth-only one-stop centers in Florida and Wisconsin. 
In addition, local boards in Alaska, Arizona, Arkansas, California, 
Colorado, the Federated States of Micronesia, Idaho, Louisiana, 
Missouri, New Jersey, New York, Puerto Rico, Tennessee, and Texas
reported having one or more youth-only one-stop centers. 

[20] The average dollar amounts and percentages are based on responses 
to relevant questionnaire items from 65 local boards that described 
their workforce investment area as “a portion of a rural area” and 121 
local boards that described their area as something other than “a 
portion of a rural area.” 

[21] Among the other youth council membership categories that 
respondents cited were community and technical colleges and 
universities. 

[22] Based on calculations in which we combined two of the six response 
categories, “Very Easy” and “Easy,” in the appropriate questionnaire 
item, and in which we eliminated from the analysis any local boards 
that reported they had “Not Yet Completed [the] Task” of getting 
educators to participate on the youth council. 

[23] The Office of Youth Services in the Department of Labor’s 
Employment and Training Administration told us that the following 
states had established state-level youth councils in addition to local 
youth councils as of February 2002: California, Colorado, Florida,
Hawaii, Illinois, Indiana, Maryland, Minnesota, Nebraska, Nevada, Ohio, 
Oregon, Pennsylvania, South Carolina, and Tennessee. This list does not 
include single workforce investment area states, each of which has a 
single youth council. 

[24] Information obtained from GAO survey conducted for prior report. 
See U.S. General Accounting Office, Workforce Investment Act: Better 
Guidance and Revised Funding Formula Would Enhance Dislocated Worker 
Program, [hyperlink, http://www.gao.gov/products/GAO-02-274], 
(Washington, D.C.: Feb. 11, 2002). 

[25] For information on performance indicators for WIA adult, 
dislocated workers, and older youth, see U.S. General Accounting 
Office, Workforce Investment Act: Improvements Needed in Performance 
Measures to Provide a More Accurate Picture of WIA’s Effectiveness, 
[hyperlink, http://www.gao.gov/products/GAO-02-275], (Washington, D.C.: 
Feb. 1, 2002). 

[26] Department of Labor, Training and Employment Guidance Letter No. 
11-01, Washington, D.C., 2002. 

[27] For information on how federal, state, and local agencies have 
sought to simplify or coordinate eligibility determination processes, 
see U.S. General Accounting Office, Means-Tested Programs: Determining 
Financial Eligibility Is Cumbersome and Can Be Simplified, 
[hyperlink, http://www.gao.gov/products/GAO-02-58], (Washington, D.C.: 
Nov. 2, 2001). 

[28] For recommendations concerning performance measures for older 
youth, see U.S. General Accounting Office, Workforce Investment Act: 
Improvements Needed in Performance Measures to Provide a More Accurate 
Picture of WIA’s Effectiveness, 
[hyperlink, http://www.gao.gov/products/GAO-02-275], (Washington, D.C.: 
Feb. 1, 2002). 

[End of section] 

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