Supplemental wage data for WIOA performance

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                Performance
                 ADVISORY SYSTEM                         CORRESPONDENCE SYMBOL
            U.S. DEPARTMENT OF LABOR                     OPDR/OWI
               Washington, D.C. 20210                    DATE
                                                         June 1, 2017


ADVISORY:       TRAINING AND EMPLOYMENT GUIDANCE LETTER WIOA NO. 26-16
                OPERATING GUIDANCE for the WORKFORCE INNOVATION AND
                OPPORTUNITY ACT (referred to as WIOA)

TO:             STATE AND LOCAL STAKEHOLDERS IN THE WORKFORCE
                INNOVATION AND OPPORTUNITY ACT
                STATE WORKFORCE AGENCIES
                STATE WORKFORCE ADMINISTRATORS
                STATE WORKFORCE LIAISONS

FROM:           Byron Zuidema /s/
                Deputy Assistant Secretary

SUBJECT:        Guidance on the use of Supplemental Wage Information to implement the
                Performance Accountability Requirements under the Workforce Innovation and
                Opportunity Act

1. Purpose.
   The purpose of this guidance is to provide sub-regulatory guidance on the requirements
   established by the Workforce Innovation and Opportunity Act (WIOA) and its implementing
   regulations regarding the use of supplemental wage information, when appropriate, to assist
   in carrying out the performance accountability requirements under section 116 of WIOA.

2. Background.
   Section 116 of WIOA establishes performance accountability indicators and performance
   reporting requirements to assess the effectiveness of States and local areas in achieving
   positive outcomes for the individuals served by each of the six core WIOA programs. The
   core programs are: the Adult, Dislocated Worker, and Youth programs authorized under
   WIOA title I and administered by the U.S. Department of Labor (DOL); the Adult Education
   and Family Literacy Act (AEFLA) program authorized under WIOA title II and administered
   by the U.S. Department of Education (ED); the Employment Service (ES) program
   authorized under the Wagner-Peyser Act, as amended by WIOA title III and administered by


 RESCISSIONS                                            EXPIRATION DATE
 None                                                   Continuing


    DOL; and the Vocational Rehabilitation (VR) program authorized under title I of the
    Rehabilitation Act of 1973, as amended by WIOA title IV and administered by ED.

    On August 19, 2016, DOL and ED (the Departments) published in the Federal Register the
    WIOA Joint Rule for Unified and Combined State Plans, Performance Accountability, and
    the One-Stop System Joint Provisions (Joint WIOA Final Rule) at 81 FR 55791, which took
    effect on October 18, 2016. On December 19, 2016, the Departments released Performance
    Accountability Guidance for Workforce Innovation and Opportunity Act (WIOA) Title I, Title
    II, Title III and Title IV Core Programs1 to further clarify the requirements of the
    performance accountability system and assist States in understanding the methodologies for
    calculating levels of performance for the six primary indicators of performance, the
    operational parameters for each of the indicators, and the application of each of the indicators
    to each core program.

    This guidance provides clarification to States on the use of supplemental wage information
    (described in detail on page 6 in the section titled “Supplemental Wage Information Methods
    and Procedures”), when reliance on such information is necessary for verifying and reporting
    on the employment-related performance indicators: employment rate during the second
    quarter after exit from the program; employment rate during the fourth quarter after exit from
    the program; and median earnings during the second quarter after exit from the program.2
    The guidance also applies to the employment-related portion of the credential attainment
    indicator.3

3. Primary Indicators of Performance.
   Under section 116(b)(2)(A) of WIOA, the performance accountability indicators that apply
   across the six core programs are:
   a. Employment Rate – Second Quarter After Exit: The percentage of participants who are in
       unsubsidized employment during the second quarter after exit from the program (for title

1
  See Performance Accountability Guidance for Workforce Innovation and Opportunity Act (WIOA) Title I, Title II,
Title III and Title IV Core Programs, joint guidance issued on December 19, 2016 via the Office of Career,
Technical, and Adult Education (OCTAE) Program Memorandum 17-2, DOL Employment and Training
Administration Training and Employment Guidance Letter (TEGL) 10-16, and Rehabilitation Services
Administration (RSA) Technical Assistance Circular (TAC) 17-1.
2
  Further details on the methodology and operational parameters for each of the employment-related indicators may
be found in OCTAE Program Memorandum 17-2; DOL TEGL 10-16; and RSA TAC 17-1.
3
  20 CFR 677.155 (a)(1)(iv)(B), 34 CFR 463.155(a)(1)(iv)(B), and 34 CFR 361.155(a)(1)(iv)(B). See also OCTAE
Program Memorandum 17-2; DOL TEGL 10-16; and RSA TAC 17-1. As noted in the section below titled “Primary
Indicators of Performance,” a participant who obtains a secondary school diploma or its recognized equivalent must
meet an additional condition before they are counted as a successful outcome and included in the numerator of the
credential attainment indicator. The participant is included in the calculation “…only if the participant is also
employed or is enrolled in an education or training program leading to a recognized postsecondary credential within
one year after exit from the program.” Therefore, for the credential attainment indicator, States may elect to use
supplemental wage information to collect information on employment within one year after exit.


        I Youth, the indicator is the percentage of participants in education or training activities,
        or in unsubsidized employment during the second quarter after exit).

   b. Employment Rate – Fourth Quarter After Exit: The percentage of participants who are in
        unsubsidized employment during the fourth quarter after exit from the program (for title I
        Youth, the indicator is the percentage of participants in education or training activities, or
        in unsubsidized employment during the fourth quarter after exit).

   c. Median Earnings – Second Quarter After Exit: The median earnings of participants who
        are in unsubsidized employment during the second quarter after exit from the program.

   d. Credential Attainment: The percentage of those participants enrolled in an education or
        training program (excluding those in on-the-job training (OJT) and customized training)
        who attain a recognized postsecondary credential or a secondary school diploma, or its
        recognized equivalent, during participation in or within one year after exit from the
        program. A participant who has attained a secondary school diploma or its recognized
        equivalent is included in the percentage of participants who have attained a secondary
        school diploma or its recognized equivalent only if the participant is also employed or is
        enrolled in an education or training program leading to a recognized postsecondary
        credential within one year after exit from the program.

   e. Measurable Skill Gains: The percentage of program participants who, during a program
        year, are in an education or training program that leads to a recognized postsecondary
        credential or employment and who are achieving measurable skill gains, defined as
        documented academic, technical, occupational, or other forms of progress, towards such
        a credential or employment.

   f.   Effectiveness in Serving Employers: WIOA sec. 116(b)(2)(A)(i)(VI) requires the
        Departments to establish a primary indicator of performance for effectiveness in serving
        employers. The Departments are piloting three approaches designed to gauge how well
        the workforce system is meeting critical workforce needs of the business community.

4. Availability of Social Security Numbers (SSNs) and Wage Records to Collect
   Employment Information.
   Section 116(i)(2) of WIOA requires States to use quarterly wage records, consistent with
   State law, to measure their progress on satisfying State and local performance accountability
   indicators. The Joint WIOA Final Rule implements these requirements in 20 CFR 677.175,
   34 CFR 463.175, and 34 CFR 361.175 by requiring States to use, consistent with State law,
   quarterly wage record information such as intrastate and interstate wages paid to an


    individual, an individual’s SSN, and the Federal employer identification number of the
    employer paying the wages to the individual.

    However, the Departments recognize that in particular circumstances (further described
    below) there are challenges the core programs face in tracking the progress of individuals for
    whom obtaining a quarterly wage record match may not be possible. In order to ensure that
    programs may track the participants for performance accountability purposes even if their
    information is not contained in the State’s quarterly wage record system, the Joint WIOA
    Final Rule permits States to use “other information as is necessary to measure the progress of
    those participants through methods other than quarterly wage record information” if quarterly
    wage records are not available for a participant (20 CFR 677.175(a)(3), 34 CFR
    463.175(a)(3), and 34 CFR 361.175(a)(3)).

    Matching a participant’s SSN against quarterly wage record information is the most effective
    means for determining employment status and earnings for a program participant. However,
    a quarterly wage record match will not be possible in all circumstances. Eligibility to
    participate in any of the programs under WIOA is not contingent upon the individual
    providing an SSN.4 More broadly, since the performance indicators require reporting on all
    participants,5 States are encouraged to develop a method for quantifying the performance
    outcomes of participants who do not provide SSNs or for whom wage records are not
    available in order to include them in the calculation of levels of performance for each of the
    core programs.

5. Circumstances for Collecting Employment-Related Data Using Supplemental Methods
   for Performance Reporting Purposes.
   For purposes of the employment-related performance indicators, a participant’s status in
   unsubsidized employment and quarterly earnings may be determined by a variety of data
   sources. To the extent it is consistent with State law, direct Unemployment Insurance (UI)
   wage match, obtained through either State UI data or the out-of-State wage record data

4
 See 81 FR at 55838.
5
 Although the definition of “participant” is consistent across the core programs, there are some slight differences to
account for programmatic requirements. For the WIOA title I Adult, title I Dislocated Worker, title II AEFLA, and
title III Wagner-Peyser Act ES programs, a participant is a reportable individual who has received services other
than the services described in 20 CFR 677.150(a)(3), 34 CFR 463.150(a)(3), and 34 CFR 361.150(a)(3), after
satisfying all applicable programmatic requirements for the provision of services, such as eligibility determination.
For the title I Youth program, a participant is a reportable individual who has satisfied all applicable program
requirements for the provision of services, including eligibility determination, an objective assessment, and
development of an individual service strategy, and received one or more of the 14 WIOA Youth program elements
identified in sec. 129(c)(2) of WIOA. For the VR program, a participant is a reportable individual who has applied
and been determined eligible for VR services, has an approved and signed Individualized Plan for Employment, and
has begun to receive services. See 20 CFR 677.150(a); 34 CFR 463.150(a); 34 CFR 361.150(a); and OCTAE
Program Memorandum 17-2; DOL TEGL 10-16; and RSA TAC 17-1 issued December 19, 2016.


    exchange, via appropriate agreement,6 will be the primary data source for verifying
    participant outcomes for purposes of calculating levels of performance for the employment-
    related indicators and will be used when available. UI wage records include private sector
    and government employer wage reports, such as:

        State government employment records;
        Local government employment records;
        Judicial employment records; and
        Public school employment records.

    While most forms of employment in a State’s workforce will be reported via employer tax
    filings in the UI wage records system as noted above, certain types of employers and
    employees are excluded from coverage under Federal and State UI laws. For program
    participants engaged in these types of employment, and for participants for whom the State
    does not have an SSN on record, States may use supplemental wage information and wage
    data from other reliable sources to collect employment-related data necessary for calculating
    levels of performance.

    Individuals for whom a quarterly wage record match would not be available through the State
    UI data system include but are not limited to:

        Federal employees;
        Military employees; or
        Individuals who are self-employed.

    States that are not signatories to the Wage Record Interchange System (WRIS) cannot access
    State UI wage records through the WRIS. Furthermore, performance reporting for the
    AEFLA and VR programs is not a permissible query of the WRIS, and the WRIS cannot be
    used to obtain UI wage records to carry out performance reporting for the AEFLA and VR
    programs. However, performance reporting for the AEFLA and VR programs will be a
    permissible query of the State Wage Interchange System (SWIS). That is, the SWIS can be

6
 The Wage Record Interchange System (WRIS) is a data sharing agreement used to exchange wage record
information for performance reporting purposes between States that are party to the data sharing agreement. WRIS,
and WRIS2, were established under the Workforce Investment Act of 1998 (WIA); the successor system under
WIOA will be known as the State Wage Interchange System (SWIS). Section 116(i)(2) of WIOA continues the
requirement that States use wage records to assess performance and the Secretary of Labor’s authority to facilitate the
exchange of wage data across States. Additionally, section 116 of WIOA identifies core programs administered by
the Departments and their performance accountability responsibilities, which include the use of UI wage records for
performance accountability purposes. As of the date of this guidance, the Departments are working with States to
establish the new SWIS Data Sharing Agreement that builds on the established protocols, permissions, and
protections under the WRIS and WRIS2 and will help to facilitate States’ compliance with WIOA’s performance
reporting requirements.


used to obtain UI wage records to carry out performance reporting for the AEFLA and VR
programs. As has been true with the WRIS, States that are not signatories to the SWIS will
not be able to access State UI wage records through the SWIS.

Sources of supplemental wage information for the types of employees described above
include:

      Federal employment records, such as military employment records, or records from the
       U.S. Department of Defense, U.S. Postal Service, and U.S. Office of Personnel
       Management;
      State New Hires Registry;
      State Department of Revenue or Taxation;
      Railroad Retirement System; and
      Other forms of supplemental wage information (see description in the next section).

It is important for States to consider the following when deciding to voluntarily collect
supplemental information for purposes of calculating levels of performance for the
employment-related indicators:

     i.   States are required to report a participant’s status in unsubsidized employment during
          the second quarter and fourth quarter after exit. In addition, a participant’s quarterly
          earnings may only be reported for calculation of median earnings during the second
          quarter after exit, upon direct wage record match or collection of supplemental wage
          information. While median earnings are not reported for the fourth quarter after exit,
          either a direct wage record match or supplemental wage information is required to
          determine a participant’s employment status in the fourth quarter after exit.

    ii.   Within each quarter after exit for which wages are required pursuant to the
          performance accountability indicators, if a direct wage match is used to determine
          both employment status and wages for the period, then the same direct wage match
          record must be used for both wages and employment status. Likewise, if
          supplemental wage information is used to determine both employment status and
          wages within the same reporting period, then the same supplemental wage
          information must be used for both wages and employment status. There is no
          requirement that the same direct wage record match or supplemental wage
          information be used across multiple reporting periods, particularly in the event that
          the individual’s employment status changes making the employment and wage
          verification method initially used not practicable or ideal. The Departments
          recommend that States use direct wage record matches whenever possible because
          such method yields the most reliable data.


     iii.    When calculating levels of performance, States that elect not to use supplemental
             wage information are still expected to include participants who do not have the
             necessary data to complete a wage record match in the denominator. In so doing,
             those individuals would be counted as negatives (0 in the numerator) when
             calculating levels of performance for the second and fourth quarter employment
             status indicators. Participants will be excluded from the median earnings indicator
             calculation if the employment rate second quarter after exit is a negative (0).

      iv.    For States that elect to use supplemental wage information, States must ensure that a
             participant’s quarterly earnings used for reporting the median earnings indicator
             (second quarter after exit) only reflect those wages that are actually paid to the
             participant during the quarter.

6. Supplemental Wage Information Methods and Procedures.
   For States that determine the need to collect supplemental wage information for the
   employment-related indicators, acceptable forms of supplemental wage information, relevant
   to the core program, include, but are not limited to, the following:

    Tax documents, payroll records, and employer records such as:
     Copies of quarterly tax payment forms to the Internal Revenue Service, such as a Form
       941 (Employer’s Quarterly Tax Return);
     Copies of pay stubs (minimum of two pay stubs); or
     Signed letter or other information from employer on company letterhead attesting to an
       individual’s employment status and earnings.

    Other supplemental wage records:
     Follow-up survey (self-reported) from program participants;
     Income earned from commission in sales or other similar positions;
     Detailed case notes verified by employer and signed by the counselor, if appropriate to
       the program;
     Automated database systems or data matching with other partners with whom data
       sharing agreements exist;
     One-Stop operating systems’ administrative records, such as current records of eligibility
       for programs with income-based eligibility (e.g., Temporary Assistance for Needy
       Families (TANF) or Supplemental Nutrition Assistance Program ( SNAP)); or
     Self-employment worksheets signed and attested to by program participants.7


7
 Earnings (or net profit) can be calculated by subtracting total expenses from gross receipts. Not all self-employed
individuals receive a salary, but the funds that represent income over expenses that are available to be invested back
into the business are considered earnings.


    The Departments recommend the following procedures when a State determines the need to
    collect supplemental wage information:

    A. Time Period for Collecting Supplemental Wage Information
         As described above, for purposes of calculating levels of performance for the
         employment rate indicators, States must collect data on participants’ employment status
         during the second and fourth quarters after the participant exits the program8 and, for
         purposes of calculating levels of performance for the median earnings indicator, States
         must collect data on participants’ wages during the second quarter after exit from the
         program. Follow-up to collect supplemental wage information may be conducted by the
         State, local programs, or a third-party contractor. The timing for collecting supplemental
         wage information may vary based on whether the agency knows or expects that UI wage
         data will not be available for a participant following the exit from a program.

         The need for supplemental wage information for some individuals may not become
         apparent until no match is found in direct UI wage records, or in federal or military
         employment records, which become available on a time-lagged basis. UI wage data for
         the employment rate and the median earnings indicators during the second quarter will
         not become available until the latter part of the third quarter after exit, and UI wage data
         for the education or employment rate during the fourth quarter after exit will not become
         available until the latter part of the fifth quarter after exit.

         However, when the agency knows or predicts that UI wage data will not be available for
         individuals (such as those participants who did not provide an SSN, or for participants
         not covered by UI wage data, such as those who received entrepreneurial or self-
         employment training), States do not need to wait two quarters after the close of the
         second and fourth full quarters after exit to formally document that UI wage data are not
         available and begin collection of supplemental wage information. The optimal time to
         collect supplemental wage information is as soon as possible following the close of the
         second and fourth full quarters after exit. In general, the Departments recommend the
         programs remind participants, before program exit, that they or their employers may be
         contacted to obtain confirmation of employment status and earnings, and to explain the
         expected timeframe for those follow-up contacts. While this reminder is applicable to all
         participants, it is especially important for those participants for whom UI wage data are
         not available.


8
 For the purpose of the employment portion of the credential rate indicator, States must collect data on participants’
employment status each quarter after exit within one year after exiting the program. (See Table 1: Timeline for
Commencing Data Collection for Employment-Related Performance Indicators).


Table 1, below, summarizes the times when data match or supplemental wage data are to be collected.
 Table 1: Timeline for Commencing Data Collection for Employment-Related Performance Indicators
    Performance Indicatora         UI Wage Data Becomes Available             Collection of Supplemental Wage
                                                                                   Information May Beginb
Employment Rate – Second
Quarter after Exit                 During third or fourth quarter after exit Beginning third quarter after exit
(including Title I Youth)
Employment Rate – Fourth           During fifth or sixth quarter after exit
Quarter after Exit                 (first or second quarter, next program       Beginning fifth quarter after exit
(including Title I Youth)          year)
Median Earnings – Second
                                   During third or fourth quarter after exit Beginning third quarter after exit
Quarter after Exit
Credential Attainment –            During second or third quarter after
                                                                                Beginning second quarter after exit
within 1 Year after Exit           exit
a
  For all performance indicators, exit is the point after which a participant who has received services through any
program meets the criteria for exit from that program, or meets the criteria for exit under an applicable common exit
policy (20 CFR 677.150(c), 34 CFR 463.150(c), and 34 CFR 361.150(c)).
b
  For individuals for whom the agency knows or predicts UI wage data will not be available (such as those
participants who do not provide an SSN, or for participants receiving entrepreneurial or self-employment training),
States should begin collecting supplemental wage information as close to the reference period as possible.


         Participants who provide an SSN and have exited a program, but for whom information is
         not yet available, are not included in performance calculations until such data
         subsequently become available. The Departments expect that UI employer tax record
         data for these indicators will generally be available, since there is a two-quarter lag built
         into the reporting periods to allow time for reporting participant exit and direct UI wage
         record match, and for obtaining supplemental wage information if a direct UI wage
         record match, or Federal or military employment record, is not yet available.9 In order to
         ensure data are available and reported consistently for all participants, UI data should be
         reported four quarters after exit for second quarter wage and employment information,
         and six quarters after exit for fourth quarter information. This allows for a one-quarter
         lag in the reporting of UI wages by employers and an additional one-quarter lag for
         reporting by the core programs.

                  Example: If a participant exits the program between July 1, 2016 and September
                  30, 2016 (first quarter of program year (PY) 2016), the participant will not be
9
 After the two-quarter lag concludes, if the information is still not available, wages will be converted to $0
permanently and employment status will be reported as not employed. Wages reported as $0 will indicate that the
participant was unemployed in the second quarter after exit, counting as a negative outcome for purposes of
calculating levels of performance for the Employment Rate Second Quarter after Exit indicator and excluding that
participant from the calculations of levels of performance for the Median Earnings Second Quarter after Exit
indicator. Likewise, if neither a wage record match nor supplemental wage information is available following a
two-quarter lag after the end of the fourth quarter following program exit, the participant will be reported as
unemployed in the fourth quarter after exit.


                     included in the Employment Rate – Second Quarter After Exit until the quarterly
                     report for the quarter ending September 30, 2017 (first quarter of PY 2017) and
                     the annual report for PY 2017 for the period ending June 30, 2018.

           Quarterly data reporting is required for all core programs except for the AEFLA program
           (i.e., the Adult, Dislocated Worker, Youth, Wagner-Peyser Act ES, and VR programs)
           (20 CFR 677.235(a), 34 CFR 463.235(a), and 34 CFR 361.235(a)). States must report
           AEFLA data on an annual basis, but are required to collect data on a quarterly basis. To
           ensure data are collected to satisfy required reporting timelines, particularly for those
           programs reporting on a quarterly basis, States may decide to conduct supplemental wage
           information follow-up more frequently than quarterly, as more frequent follow-up may be
           more convenient or cost efficient. For example, the program could conduct continuous,
           ongoing, or monthly follow-up activities. Therefore, the Departments recommend that
           programs ensure the time lag to contact participants after they exit the program be as
           short as possible to ensure follow-up activities are successful. The longer a program
           waits to contact participants after they exit the program, the greater likelihood of a lower
           response rate which could result in less valid data.

 The timeframes when employment-related information must be reported are shown in Table 2 below:
    Table 2: Deadlines for Timely Collection of Data for Employment-Related Performance Indicators
      Exit Quarter           Report Employment               Report            Report Median            Report Credential
                                      nd
                              Rate – 2 Quarter       Employment Rate –       Earnings by End of:           Attainment
                                                            th
                               (including Title I         4 Quarter                                  (Employment) – within 1
                              Youth) by End of:        (including Title I                            Year after Exit by End of:
                                                      Youth) by End of:
    First Quarter (Q1)               Q1,                       Q3,                   Q1,                        Q3,
 (July 1 – September 30)      Next Program Year      Next Program Year        Next Program Year        Next Program Year
                             (four quarters later)    (six quarters later)   (four quarters later)     (six quarters later)
   Second Quarter (Q2)               Q2,                       Q4,                   Q2,                        Q4,
(October 1 – December 31)     Next Program Year      Next Program Year        Next Program Year        Next Program Year
                             (four quarters later)    (six quarters later)   (four quarters later)     (six quarters later)
   Third Quarter (Q3)                Q3,                       Q1,                   Q3,                        Q1,
 (January 1 – March 31)       Next Program Year        Second Program         Next Program Year       Second Program Year
                             (four quarters later)       Year After Exit     (four quarters later)           After Exit
                                                      (six quarters later)                             (six quarters later)
   Fourth Quarter (Q4)               Q4,                       Q2,                   Q4,                        Q2,
    (April 1 – June 30)       Next Program Year        Second Program         Next Program Year       Second Program Year
                             (four quarters later)       Year After Exit     (four quarters later)           After Exit
                                                      (six quarters later)                             (six quarters later)


B. Method for Identifying Participants Needing Follow-Up for Wage Information
   Collection Purposes
   In order to effectively identify individuals with whom the agency will need to follow up
   to collect supplemental wage information, the State’s or local area’s case management
   database needs to be capable of identifying participants who should be followed using
   supplemental methods, i.e., all participants for whom direct UI wage record match,
   Federal, or military employment records are not or were not yet available for data
   matching. Programs must also determine the appropriate information to collect from
   participants to assist in, and during, follow-up, such as: (1) participants’ SSN (if
   available) and contact information; and (2) supplemental wage information related to all
   of the employment-related performance indicators. This information needs to be
   retrievable quarterly or according to the time when States determine supplemental wage
   information follow-up is to be implemented.

   If a program uses supplemental wage information follow-up to retrieve data on any of the
   employment-related performance indicators, data must be collected on all of these
   indicators, or missing and incomplete data points will be counted as a negative when
   calculating levels of performance for the indicator(s).

C. Staff Training on Supplemental Wage Information Follow-Up Methods
   When conducting supplemental wage information follow-up, the Departments
   recommend that staff follow a uniform set of written procedures to collect data in a valid
   and reliable manner. Therefore, staff conducting the supplemental wage information
   follow-up should be trained in the implementation of the follow-up procedures, including
   what to say to former participants or their employers to encourage their cooperation,
   ways to encourage voluntary and truthful disclosure, how to document the information
   received, and how to respond to questions related to the supplemental wage information
   follow-up process. Staff should be thoroughly familiar with all procedures before
   beginning the process.

   The Departments recognize that programs and States may consider supplemental wage
   information to be a very difficult aspect of data collection, particularly since it is
   sometimes difficult to follow up in a way that produces valid and reliable results (e.g.,
   conducting follow-up surveys or other forms of self-reporting). The process includes
   determining which individuals should be included in the supplemental wage information
   follow-up; locating the individual, employer or case manager; securing his/her
   cooperation; and conducting the follow-up procedure. Maintaining contact with, or
   finding, these former participants and getting them to cooperate in the supplemental wage
   information follow-up process is critical to its success since the response rate largely
   determines the validity of the information. Locating such individuals can be difficult,


given the transient nature of some core program participants. The procedures described
below will assist States in collecting valid supplemental wage information in a timely
manner.

The validity of the follow-up process depends largely on the acceptable forms of
supplemental wage information received from participants. To help improve this aspect
of the follow-up process, it is very important that participants know how they may be
contacted later and asked about their employment outcomes. Therefore, programs should
inform participants at program entry about the supplemental wage information follow-up
process and collect extensive contact information about them, such as addresses and
phone numbers of relatives or others who may know the participants’ whereabouts over
time and employment information, if applicable. In addition, participants should be
encouraged to provide new addresses and phone numbers when they move, and programs
should implement procedures to update this information periodically while the participant
remains enrolled in the program. These procedures can greatly assist in locating former
participants months later when the supplemental wage information may need to be
collected. States should provide local programs with additional guidance to improve the
level of response.


                 Summary of Supplemental Wage Information Follow-Up Guidelines

    1. Develop a method for identifying participants to contact for follow-up.

       Best practice tip: Have staff follow a uniform set of written procedures to collect data in a valid
       and reliable (i.e., accurate and repeatable) manner.

    2. Ensure that the State has a uniform way to conduct the follow-up.

    3. Conduct the follow-up as close to the reference period as possible.

    4. Train staff to conduct the follow-up.

    5. Identify local resources available to conduct the follow-up.

    6. Implement procedures to improve the quantity and quality of participant responses.

       Best practice tip: Inform participants at program entry about the supplemental wage
       information follow-up process and collect extensive contact information about them, such as
       addresses and phone numbers of relatives or others who may know the participants’
       whereabouts over time and employment information, if applicable.

    7. Ensure that the State has a database and procedures for supplemental wage information
      reporting.


7. Action Requested.
   States are requested to distribute this information to the appropriate State and local staff.

8. Inquiries.
   Questions and comments from DOL-funded grantees may be directed to the appropriate ETA
   Regional Office and Federal Project Officer. Questions and comments from ED-funded
   grantees may be directed to the appropriate RSA State Liaison or OCTAE Area Coordinator.

9. Attachment.
   Additional Considerations when Using Supplemental Wage Information for the Core
   Programs.

Attachment (official PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2017/TEGL_26-16_Attachment_1.pdf)

Attachment 1

                Additional Considerations when Using Supplemental Wage
                           Information for the Core Programs

When collecting supplemental wage information for the core programs, the Departments
recommend that States consider the following:

    1. The varying intervals of pay schedules mean that not every quarter reflects 13 weeks’
      wages and the agency may need to make adjustments. The wage conversion chart in
      Attachment 3 to OCTAE Program Memorandum 17-2; DOL TEGL No. 10-16; and RSA
      TAC 17-1 provides a conversion tool. It is important to note that when collecting
      supplemental wage information for the median earnings indicator, programs must only
      report those wages that are actually paid to the participant during the quarter, not
      projected amounts based on the wage conversion chart.

    2. Core programs must ensure that information gathered is representative of the
      participant’s regular hours and earnings. This information can be acquired in an
      interview by program staff with the individual or the employer if the information
      obtained addressed the following information:

          Average hours scheduled per week
          Average hours actually worked per week
          Wage per hour
          Availability of paid leave
          Start and end dates of employment (or start date and still employed).

       In the case of the VR program, this detailed information would be included in the case
       notes from the meeting.

    3. Activities related to acquiring supplemental wage and earnings information must conform
      to an agency’s policies and procedures. Supplemental information reported to the core
      program must be consistent with the core program’s reporting requirements.