WIOA Planning — It Makes My head Ache

My frustration is incredibly high with the Workforce Innovation and Opportunity Act .

I was once told you can fit an elephant through a keyhole if you use a big enough shoehorn. While that may be true, but when it is all over either the door or the elephant are gonna get mangled.

And to my mind, that’s kind of where we are with this thing. And it’s not because anyone is overly incompetent, or lazy. It’s just that the design of the WIOA implementation is poorly constructed.

You see, from a planning perspective the U.S. Department of Labor has mish-mashed sequential tasks and concurrent tasks and violated the 1/3 2/3 rule along the way.

Here’s what I mean.

For Vocational Rehabilitation the new law was executable on receipt – that was last summer. Meanwhile Employment and Training had one year before implementation to figure it out – kind of. Meanwhile the regulations covering the law – which goes into full effect 1 July 2015 – are still pending review and finalization.

So here we are, states are putting together new boards, structures, and relationships based on a regulation that may or may not be adopted, in whole or in part, thus making the alignment the law is was supposed facilitate, already disjointed and unity of effort is out the window.

That’s not the worst of it – at least to my mind.

An important concept in planning is, as I said, the one-third/two third rule. Simply stated a higher headquarters only takes one third of the time available to develop a plan, and gives subordinate headquarters two-thirds of the time. This ensure higher headquarters don’t monopolize all the time.

Sound good? It works great, but apparently this technique hasn’t reached the upper echelons of US DOL and it’s driving me crazy.

Here’s why. The big state plan is due to US DOL on 1 March 2016. If you count back that would 19 months from the time the law was signed to the month it is due. One-third of that time would mean all planning guidance from US DOL should have been delivered by last December. Unfortunately, we are rolling into July and still no guidance. If US DOL released guidance today, the feds would have gobbled up two thirds of the time available. Shame on them.

The states are in unenviable position of using guidance from two years ago to make their best guess about requirements. But here is the kicker – once you backward plan the approval times and public comment periods the states should really have their plans completed no later than December 1st. And let’s face it once you get to Halloween, time seems to speed up through Thanksgiving and Christmas. If it’s not done by November, you’re a dead duck.

What a mess.


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