Supplemental wage information for WIOA performance reports, Change 1

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                Performance
                  ADVISORY SYSTEM                        CORRESPONDENCE SYMBOL
             U.S. DEPARTMENT OF LABOR                    OPDR/OWI
                Washington, DC 20210                     DATE
                                                         July 10, 2025

ADVISORY: TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 26-16,
          Change 1

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

FROM:           LORI FRAZIER BEARDEN
                Acting Assistant Secretary

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

1. Purpose. This guidance updates Training and Employment Guidance Letter (TEGL) 26-16,
   issued June 1, 2017, and developed jointly by the U.S. Departments of Labor (DOL) and
   Education (ED) (collectively, the Departments). Within ED, the Office of Career, Technical,
   and Adult Education (OCTAE) will update Program Memorandum (PM) 17-6 and the
   Rehabilitation Services Administration (RSA) will update Technical Assistance Circular
   (TAC) 17-04 to be consistent with the changes reflected herein.

   With this issuance, the Departments update the guidance to align it with changes made by the
   Workforce Innovation and Opportunity Act Effectiveness in Serving Employers Performance
   Indicator final rule (89 FR 13814 (Feb. 23, 2024)) (Final Rule), which took effect March 25,
   2024. This Final Rule defined the Effectiveness in Serving Employers primary indicator of
   performance, as required by WIOA section 116(b)(2), as Retention with the Same Employer,
   and it requires States to report the indicator as a shared indicator across the six core
   programs. This guidance also incorporates other changes to improve clarity.

   RESCISSIONS                                            EXPIRATION DATE
   TEGL 26-16                                             Continuing

2. Action Requested. States are requested to distribute this information to the appropriate State
   and local staff. Please make this information available to the appropriate program, reporting,
   performance accountability, and technical staff.

3. Summary and Background.

    a. Summary – TEGL 26-16, Change 1 rescinds and replaces TEGL 26-16, issued June 1,
       2017. These changes update the portions of the guidance that relate to Effectiveness in
       Serving Employers to align with the Final Rule.

    b. Background – This guidance, TEGL 26-16, Change 1, updates the guidance to
       incorporate the regulatory definition of Effectiveness in Serving Employers and makes
       other clarifications.

        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 participants served by each of the six core WIOA programs.

        On August 19, 2016, 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 June 11, 2024, the Departments revised the Performance
        Accountability Guidance for Workforce Innovation and Opportunity Act (WIOA) Title I,
        Title II, Title III and Title IV Core Programs, (originally released December 19, 2016),1,2
        which further clarifies the requirements of the performance accountability system and
        assists 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

1 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 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.
2
  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, June 11, 2024 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, Change 3, and Rehabilitation Services
Administration (RSA) Technical Assistance Circular (TAC) 17-01.

                                                       -2-

         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; median earnings during the second
         quarter after exit from the program; and effectiveness in serving employers.3 The
         guidance also applies to the employment-related portion of the credential attainment
         indicator.4

4. Operating Guidance.

    a. Primary Indicators of Performance.
       Under section 116(b)(2)(A) of WIOA, the performance accountability indicators that apply
       across the six core programs are:

        1. 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
         I Youth, the indicator is the percentage of participants in education or training activities,
         or in unsubsidized employment during the second quarter after exit).

        2. 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).

        3. 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.

        4. Credential Attainment – The percentage of those participants enrolled in an education or
         training program (excluding those in on-the-job training 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

3
  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, Change 3; and RSA TAC 17-1.
4
  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.

                                                       -3-

          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.

        5. 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.

        6. Effectiveness in Serving Employers –The percentage of participants in unsubsidized
          employment during the second quarter after exit from the program who were employed
          by the same employer in the second and fourth quarters after exit. For the six core
          programs, this indicator is a statewide indicator reported by one core program on behalf
          of all six core programs in the State, as described in the Departments’ joint performance
          guidance.5

    b. 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 (FEIN) 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 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.

5
    OCTAE Program Memorandum 17-2; DOL TEGL 10-16, Change 3; and RSA TAC 17-01.

                                                  -4-

      Eligibility to participate in any of the programs under WIOA is not contingent upon the
      individual providing an SSN.6 More broadly, since the performance indicators require
      reporting on all participants,7 the Departments encourage States 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.

    c. 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, quarterly earnings, and employer 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
       exchange, via appropriate agreement,8 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. Certain categories

6
  See 81 FR at 55838.
7
  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 17-01 issued December 19, 2016.
8
  The State Wage Interchange System (SWIS) is a data sharing agreement used, among other things, to exchange
wage record information for performance reporting purposes between States that are party to the data sharing
agreement. 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.

                                                         -5-

of employment, such as entrepreneurial employment, Federal employment, employment
with the U.S. Postal Service and the military, and farmwork, are not reflected in State UI
wage record databases. 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.

States that are signatories to the State Wage Interchange System (SWIS) can access other
states’ UI wage records through the SWIS. States may use the SWIS to obtain UI wage
records to carry out performance reporting for the six WIOA core programs.

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.

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.

                                          -6-

   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.

   v.    When determining if a participant was employed by the same employer in the second
         and fourth quarters after exit, as required by the Effectiveness in Serving Employers
         measure, as defined in the Joint Final Rule, the use of a primary data source for
         verifying a FEIN match is preferable. If the supplemental wage information obtained
         does not contain a FEIN, States should establish other details that confirm the
         employer as the same, thereby satisfying the requirements of the performance
         indicator as defined by the Joint Final Rule.

d. 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:

                                             -7-

    ▪    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:
    ▪ Post-Exit follow-up for the purposes of collecting employment and wage information
       (self-reported) from program participants;
    ▪ Detailed program staff case notes with employment and wage information obtained from
       the employer;
    ▪ Automated database systems or data matching with other partners with whom data
       sharing agreements exist; or
    ▪ Self-employment worksheets signed and attested to by program participants.9

    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 and effectiveness in serving employers indicators, States must collect
         data on participants’ employment status (including employer) during the second and
         fourth quarters after the participant exits the program10 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, all of 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

9
 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.
10
   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).

                                                          -8-

       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.

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              Collection of Supplemental Wage
                                        Available                        Information May Beginb
 Employment Rate –
 Second Quarter after         During third or fourth quarter after
                                                                     Beginning third quarter after exit
 Exit                         exit
 (including Title I Youth)
 Employment Rate –            During fifth or sixth quarter after
 Fourth Quarter after Exit    exit (first or second quarter, next    Beginning fifth quarter after exit
 (including Title I Youth)    program year)
 Median Earnings –
                              During third or fourth quarter after
 Second Quarter after                                                Beginning third quarter after exit
                              exit
 Exit
 Credential Attainment –      During second or third quarter
                                                                     Beginning second quarter after exit
 within 1 Year after Exit     after exit
                              Second quarter (Q2) employer
                              information - During third or
                                                                     Q2 employer information -
                              fourth quarter after exit
 Effectiveness in Serving                                            Beginning third quarter after exit
                              Fourth quarter (Q4) employer
 Employers                                                           Q4 employer information -
                              information - During fifth or sixth
                                                                     Beginning fifth quarter after exit
                              quarter after exit (first or second
                              quarter, next program year)

                                                  -9-

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 the quarter when
         such data is expected to 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.11 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, 2024 and September
                  30, 2024 (first quarter of program year (PY) 2024), the participant will not be
                  included in the Employment Rate – Second Quarter After Exit until the quarterly
                  report for the quarter ending September 30, 2025 (first quarter of PY 2025) and
                  the annual report for PY 2025 for the period ending June 30, 2026.

         Jointly administered WIOA regulations require all core programs except for the AEFLA
         program (i.e., the Adult, Dislocated Worker, Youth, Wagner-Peyser Act ES, and VR
         programs) to report quarterly wage data (20 CFR 677.235(a), 34 CFR 463.235(a), and 34
         CFR 361.235(a)). Pursuant to OMB Control Number 1830-0027, States must report
         aggregate AEFLA data on an annual 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

11
  After the two-quarter lag concludes, if the information is still not available, earnings must be converted to $0
permanently and employment status must 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.

                                                        - 10 -

              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                Report                Report            Report Median           Report                 Report
 Quarter           Employment            Employment          Earnings by End        Credential          Effectiveness in
                     Rate – 2nd           Rate – 4th               of:             Attainment          Serving Employers
                      Quarter              Quarter                               (Employment) –            by End of:
                 (including Title I   (including Title I                          within 1 Year
                  Youth) by End        Youth) by End                            after Exit by End
                        of:                   of:                                       of:
    First               Q1,                  Q3,                    Q1,                Q3,                    Q3,
   Quarter         Next Program         Next Program           Next Program       Next Program         Next Program Year
    (Q1)             Year (four              Year                  Year                Year            (six quarters later)
  (July 1 –        quarters later)    (six quarters later)     (four quarters   (six quarters later)
September                                                          later)
     30)
   Second              Q2,                   Q4,                    Q2,                Q4,                    Q4,
   Quarter        Next Program          Next Program           Next Program       Next Program         Next Program Year
    (Q2)           Year (four                Year                  Year                Year            (six quarters later)
 (October         quarters later)     (six quarters later)     (four quarters   (six quarters later)
     1–                                                            later)
December
     31)
    Third              Q3,                   Q1,                    Q3,                Q1,                    Q1,
   Quarter        Next Program         Second Program          Next Program      Second Program         Second Program
    (Q3)           Year (four           Year After Exit            Year           Year After Exit        Year After Exit
(January 1        quarters later)     (six quarters later)     (four quarters   (six quarters later)   (six quarters later)
  – March                                                          later)
     31)
   Fourth              Q4,                   Q2,                    Q4,                Q2,                    Q2,
   Quarter        Next Program         Second Program          Next Program      Second Program         Second Program
    (Q4)           Year (four           Year After Exit            Year           Year After Exit        Year After Exit
 (April 1 –       quarters later)     (six quarters later)     (four quarters   (six quarters later)   (six quarters later)
  June 30)                                                         later)

      B. Method for Identifying Participants Needing Post- Exit Supplemental Wage
         Information.
              In order to effectively identify individuals with whom the agency will need to collect
              supplemental wage information, the State’s, or local area’s, case management database

                                                             - 11 -

   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 the participant is willing to provide it) 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 at the time when States determine
   supplemental wage information is necessary.

   If a program uses supplemental wage information 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 Collection Activities.
   When conducting supplemental wage information collection activities, 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
   collection activities should be trained in the implementation of the post-exit 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 collection 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 gather in a way that produces valid and reliable results. The
   process includes determining which individuals should be included in the supplemental
   wage information collection; locating the individual, employer or case manager; securing
   his/her cooperation; and conducting the data collection procedure. Maintaining contact
   with, or finding, these former participants and getting them to cooperate in the
   supplemental wage information collection 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 data collection process depends largely on the acceptable forms of
   supplemental wage information received from participants. To help improve this aspect

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       of the 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 collection
       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 Collection Guidelines

    1. Develop a method for identifying participants to contact for post- exit supplemental data.

        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 process.

    3. Conduct the outreach as close to the reference period as possible.

    4. Train staff to conduct the outreach for post exit supplemental data.

    5. Identify local resources available to conduct the process.

    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 post exit 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.

5. 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.

                                                  - 13 -

6. References.
   • Workforce Innovation and Opportunity Act, Pub. L. 113-128;
   • WIOA Joint Rule for Unified and Combined State Plans, Performance Accountability,
      and the One-Stop System Joint Provisions, 81 Fed. Reg. 55791 (Aug. 19, 2016);
   • WIOA Joint Performance Accountability Information and Reporting System, OMB
      Control Number 1205-0526;
   • Information on title II requirements can be found at https://aefla.ed.gov/;
   • Information on title IV requirements can be found at https://www.ed.gov/about/ed-
      offices/osers;
   • Employment and Training Administration source for WIOA requirements:
      https://www.dol.gov/agencies/eta/wioa/; and
   • The Performance and Results website addresses how performance is measured, reported,
      and evaluated at the Employment and Training Administration:
      https://www.dol.gov/agencies/eta/performance/.

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

                                          - 14 -

                                                                                   Attachment I

                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, Change
      3; and RSA TAC 17-01 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; and
       ▪   Start and end dates of employment (or start date and still employed).

    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.