VETS Proposes Rule for States to Measure Employment Services for Veterans
A rule to measure and improve employment services to Veterans by state grantees was proposed by the Veterans’ Employment and Training Service (VETS). VETS is the agency of the Department of Labor with principal responsibility for monitoring the performance of state employment service delivery systems, with respect to the services received and outcomes experienced by Veterans. Under the Jobs for Veterans Act, the agency has the right to “establish…a comprehensive performance accountability system” for state Veteran employment agencies. While this rule does not impact government contractors directly, it is potentially a first step in agency efforts to develop national employment standards for Veteran employment from the VETS-100/100A reports—which could then be incorporated into a utilization analysis of contractors’ workforces.
VETS has been collecting data from each state on the Entered Employment Rate (EER) achieved for Veterans and eligible persons on the VETS-200C report, which divides the number of Veterans with successful placements by the number of Veterans seeking assistance. Since these data collection measures have been in place for several years, VETS has indicated there is enough information to establish a uniform national threshold Veteran employment rate.
Once determined, the uniform national threshold would be used to determine deficiencies in state performance in placing covered Veterans. If the state has an EER less than the national standard, along with other factors indicated by VETS, the state may be determined as deficient. In those cases in which a state is determined to be deficient, VETS will require a review of the state’s policies in the form of a corrective action plan, offer technical assistance to the state, and initiate corrective actions to improve the employment services offered to Veterans. VETS believes this uniform national threshold EER is a valid criterion for evaluating each state because the methodology is reasonable, easy to understand, and likely to promote continuous improvement in the entered employment outcomes achieved for Veterans and eligible persons.
VETS will determine the national EER by averaging the state percentages. To determine the uniform national threshold, the agency has proposed using 90% of the calculated state average, and will then use the any difference rule to determine if the state is statistically deficient. In the following example, for the program year, the national EER is 65.2%, and the uniform national threshold EER is 58.7% (90% of 65.2%):
- State A achieved an EER of 63.5%. This state would be exempt from a deficiency review based solely on statistics because the EER exceeds the uniform national threshold.
- State B achieved an EER of 58.7%. This state would be exempt from a deficiency review based solely on statistics because the EER equals the uniform national threshold.
- State C achieved an EER of 58.0%. This state would be considered subject to a deficiency review because it failed to meet or exceed the uniform national threshold.
If VETS' review determines a state to be deficient, in order to receive the upcoming program year's Jobs for Veterans State Grant, the state will be required to develop a Corrective Action Plan (CAP) to improve the rate for Veterans in the state. Each CAP is due to the Grant Officer's Technical Representative by June 30 of each year.
If you have any questions about the VETS proposed rule, please contact your Berkshire representative at 800.882.8904 or email bai@berkshireassociates.com.