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Reading Assessment for JTPA Title IV-A Programs

To clarify previous instructions and provide additional rationale for the new reading assessment reporting requirement.


All Native American Grantees


HERB FELLMAN PAUL A. MAYRAND Chief Director Division Indian and Native Office of Special Targeted American Programs Programs


July 22, 1991

Expiration Date
June 30, 1995
Rescissions:    None.
Text :
Reference. DINAP Bulletin 90-24, dated March 1-3, 1991. Background. DINAP Bulletin 90-24 introduced the new Employability Enhancement performance measure which is designed to give grantees credit for improving participants' knowledge, abilities and skills. Paragraph 3.f. of the Bulletin advised grantees that the Annual Status Report has been revised to capture data on various types of enhancements. It also imposed a requirement that all grantees assess the reading level of all participants at time of entry into the Section 401 program. It further stated that, for some outcomes, some grantees would need a broader approach and would have to assess a participant's employability at the time of program entry. Also, all grantees were encouraged to adopt an employability development plan to record increases in employability, to measure progress and to capture data to support reported outcomes. This policy caused some concern at the recent DINAP sponsored TAT seminars in January-February 1991 and generated considerable discussion at the recent Advisory Committee meeting in Spokane. Written comments were received subsequently from grantees. ETA of met to discuss and resolve these issues and concerns. In the meantime, it was determined that about forty percent of the grantees are already testing participants. In addition, OMB suggested the following language receding testing: ... "all grantees must offer to administer a reading test to all participants prior to service delivery. However, grantees shall permit individual participants to refuse the test..." The attached Q&A paper on assessment addresses the most frequently raised issues and concerns. In addition, there will be more training on this requirement at seminars during August-September 1991. Details will be provided in a forthcoming DINAP bulletin. Information. The reading assessment policy is in effect beginning July 1, 1991. However, grantees need to note the following clarifications and special instructions: a. Clarification of DINAP Bulletin 90-24 In reference to paragraph 3.f., grantees will obtain reading scores at intake whenever possible. Grantees are encouraged to assess for reading levels once it has been established that the eligible applicant has no existing score from a school or GED program within the last 12 months, or has acquired a four-year college degree, or is in a special circumstance where he or she is unable to be assessed at the intake site. See attached Q and A, Question number 6 for more details. Furthermore, grantees should be advised that the phrase "to assess a participant's employability" refers to other terminee characteristics which are listed as "multiple barriers to employment" such as teen parents, lacks significant work history, poor math skills, or substance abuse, etc. This phrase means that grantees should determine if a participant has multiple barriers to employment; it does not mandate grantees to conduct aptitude testing. b. Special Instructions for PY 1991 PY 1991 is considered a transition year for INA grantees to phase in a reading assessment capability for all applicants. Grantees are expected to develop this capacity during the second quarter of PY 91 and then implement an assessment procedure for all applicants during the third quarter. Summer youth participants are exempt from the reading assessment during the Summer of 1991. Grantees will not be penalized for failure to implement a total assessment procedure for PY 1991. Expenses to conduct reading assessments may be charged as a training cost (see CFR 632.38(e)). Action. Grantees are requested to review the attached Q and A paper, distributing copies as necessary to staff who will be involved in these activities. Questions. Contact your DINAP Federal Representative.

Attachments :
UNDERSTANDING THE READING ASSESSMENT REQUIREMENT Starting July 1, 1991, Indian and Native American (NA) grantees will be required to collect and report reading level data on JTPA applicants determined eligible for JTPA services; however, applicants may refuse to be tested. PY 91 will be a transition year for all grantees to adjust their master plans and management information systems to include the reading requirement information. During this year grantees will not be penalized for failure to implement a total assessment program and will not affect a grantee's redesignation process. If grantees are currently conducting reading assessments, these should be expanded to all applicants, except for certain cases discussed below. Clarifications and additional technical information are explained in the following questions and answers. 1. What is the purpose of testing applicants in reading? a. One of the system-wide goals for JTPA is to increase services to the hard-to-serve. This goal was recently endorsed as being appropriate for the INA program by the INA Advisory Committee. Individuals who lack basic literacy skills are widely acknowledged as being among the hardest-to-serve and illiteracy is a serious problem among the INA population. Therefore, information obtained on the reading skills of participants will enable DOL to gauge the extent of services provided to individuals most in need. b. DOL believes that a reading assessment requirement will be a useful tool in both demonstrating its commitment to increasing services to those who lack literacy skills as well as informing grantees of reading deficiencies of many persons who are eligible for services. As a consequence, it is hoped, that services for the proportion of persons with reading deficiencies will increase over time. c. Having information on the basic skills of participants can substantially enhance the power of the performance standards adjustment models, resulting in adjustments to standards that are more equitable and precise. Should the percent of terminees reading below the 7th grade level be incorporated in the adjustment model in the future, grantees will know that their standards will be lowered if they serve more persons with reading deficiencies. In this way, service to this hard-to-serve target group might be increased. d. DOL firmly believes that long-term employability and earnings of participants can be significantly enhanced if programs address each participants' needs through reading assessment. Literacy is critical to success in the labor market which is why remediating reading deficiencies must be incorporated in the 401 program. By knowing the reading skills of all program participants, grantees will be in a much better position to design a plan of services specifically tailored to the needs of each individual. For reasons mentioned above, DOL believes that the introduction of reading assessment will be a worthwhile investment that can substantially enhance the quality of the program and help grantees better serve the needs of their people. 2. Why can't grantees provide reading scores only for persons who enter classroom training? Helping grantees tailor the course of training to the needs of participants is only one of the reasons why reading tests are being required. Enhancing DOL's information gathering function, encouraging services to the hard-to-serve, and improving the equity of the performance standards adjustments are also important motivations, as suggested by the answer to the previous question. For these reasons, all participants are to be tested for reading competence. Exceptions are discussed below. 3. Is the reading tests were used to screen applicants? Grantees should not use the results of the reading test to screen out applicants who score poorly. On the contrary, it is hoped that the use of reading tests will increase the quality and intensity of services provided to persons with reading deficiencies. 4. Can grantees wait to obtain a test score after initial screenings? If so, how long can they wait? DOL recognizes that intake may be an inappropriate time to administer the reading test. Applicants may already be nervous or reluctant to enroll and asking them to take a test may only increase these feelings. Moreover, the intake process already is time-consuming and it may be inconvenient both to the participant and the grantee to extend its length to accommodate the reading test requirement. Further, some grantees serve large, remote areas making testing difficult at intake. Finally, some grantees may arrange for other agencies (e.g., schools or adult learning centers) to administer the reading test, and, if so, the date of test administration may need to be scheduled. For any of these reasons, a grantee may prefer to test its participants' reading skills some time after intake. The grantee should feel free to do so. However, testing should occur before the participant has received any substantial reading remediation because the reading level, to be reported on the Annual Status Report, is designed to capture participants' levels of competency before they have been enhanced through program participation. 5. What happens if an applicant totally refuses to be tested? Applicants who meet the eligibility criteria for program participation should not be denied services solely because they refuse to be tested for reading. Neither should applicants be forced in any way to undergo testing. Thus, if the applicant refuses to be tested, the program will continue to serve that individual and simply not complete this reporting category. However, the grantee should note in the Remarks section of the ASR the number of terminees who were not tested, so that DOL can subtract out these terminees in computing the percentage of terminees who read below the seventh grade level served by the grantee. Failure to make this note when appropriate will cause the grantee's percentage of terminees, reading below the seventh grade level, to be understated and could result in its being given performance standards in the future that are too stringent. In any case, grantees are required to make every effort to administer reading tests to all program, applicants. Developing rapport with potential participants and attempting to address their concerns are steps each grantee should take to increase an applicant's cooperation. For example, applicants who are reluctant to be tested can be assured that the results of the reading test will not be used to deny them services nor is it possible for them to "fail" the test. They should be informed that the purpose of the reading test is to ensure that individuals receive the training services that are just right for their needs. It is only after these efforts have failed that the grantee not test a participant. NOTE: Failure to assess participants incurs no penalties -- similar to failure to report and other characteristics. 6. Are there acceptable tests grantees can use? Any, recognized reading test that can be scaled to a grade equivalency is an acceptable instrument. A partial list of such tests, with information on their costs and the time they take to administer, has been made available to grantees by DOL. Tests can be administered either by the grantee, by a service provider (e.g., a tribal school providing initial assessment as part of its classroom training), or by some other agency with whom the grantee works out a cooperative agreement. Currently, INA grantees are using some of the following testing instruments: TABE, ABLE, ABTICOM, BOLT, PACE, COPS, CAPS, COPES, CLOZE, WRAT, GATBE, GATFS, Schlossen, and Job Corp Reading Test. Testing of all participants may not be necessary. For example, evidence of school or program records, achievement of a GED or college degree may be sufficient to determine that a person is reading above the seventh grade level. Further, the grantee need not administer a reading test to participants who had been tested elsewhere within one year prior to the date of their enrollment in the INA program (e.g., participants who were tested by a non-Section 401 JTPA program or by a high school for those who recently were students), as long as the grantee has access to these scores (confidentiality restrictions may preclude this in many cases). On the other hand, individuals who fail to comprehend simple written instructions or read signs would not have to be subjected to testing to determine they are reading below the seventh grade level. 7. Are resources available to assist grantees who cannot afford to purchase testing materials? Some reading tests developed by private testing agencies are proprietary, and their use will require the grantee to pay a fee, usually in the form of a dollar amount per copy of the testing booklet. For the sake of cost grantees may want to consider using a nonproprietary test, for which no fee is charged. Otherwise, grantees can consider forming cooperative relationships with other agencies. For instance, some funding for testing may be available from federal or state adult literacy programs. In fact, more than half of the INA grantees who currently assess their participants obtain cost-free testing services from tribal colleges, state colleges, or local school districts.

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