We have reviewed the Department of Labor (DOL), Office of Inspector General's (OIG) draft report addressing the sustainability of Iowa's School-to-Work (STW) initiative. Overall, we are pleased that most of DOL OIG's results for the 11 identified sustainability elements appear to indicate Iowa's STW initiative will be sustained after Federal funding ceases. This favorable picture fits our sense that Iowa is making good progress in implementing its statewide STW plan. Under the School-to-Work Opportunities Act (STWOA) of 1994, each State has substantial flexibility to design a comprehensive STW system within the framework of the legislation.

Iowa has provided us with a copy of their response to the DOL OIG draft report, which is attached for your information. As a general statement, we concur with Iowa's responses to the report's recommendations. We also want to provide you with additional comments.

Recommendations No. 1 and 2

The first two recommendations are essentially the same as those contained in the DOL OIG draft and final audit reports on the sustainability of Maryland's School-to-Work initiative. Both recommend that the DOL ETA Assistant Secretary collaborate with Iowa's Department of Education (DE) and the State's interdepartmental STW Administrative Team to further strengthen the sustainability of its STW system. As part of the process for responding to DOL OIG's Maryland draft report, we received legal opinions from both Departments (ED and DOL) regarding the federal government's role in working with States to meet the educational and career development goals of the STWOA. The legal counsels in both Departments determined that while the recommendations may be beneficial, the legislation does not provide the federal government the authority to enforce them. Specifically, Section 603 (State Authority) and Section 604 (Prohibition on Federal Mandates, Direction, and Control) of the STWOA appear to preclude ED, DOL, and the National School-to-Work Office from enforcing these recommendations. We continue to believe they delineate policies and decision-making solely within the purview of the State, and to suggest otherwise runs counter to the flexibility the STWOA grants to States and local entities.

DOL OIG's finding that STW is not a mandated graduation requirement in Iowa is an accurate observation. It supports Iowa's strong tradition of local control, which the draft report points out well. It is also consistent with the State's response that it "does not mandate any graduation requirements for local school districts." For that reason, this finding is not a strategy reflected in the State's plan. When DOL OIG issued essentially the same finding in Maryland's audit report, ED's Office of General Counsel concluded:

" . . . that MSDE [Maryland State Department of Education] be instructed to mandate student participation in Maryland's Career Connections as a prerequisite for high school graduation . . . appear on their face to be contrary to the terms of the STW Act and GEPA. However, while we do not think they should be included as mandatory in the final report . . . they could be included along with other possible examples of steps MSDE could take voluntarily to strengthen its sustainability of Career Connections."

Based on the State of Iowa's response, the Office of General Counsel's opinion, the State's plan, and our understanding of the flexible intent of the legislation, we disagree with the relevance of this finding. We continue to maintain this is an area solely within the State's purview.
 

Finding No. 2: "State Certification Requirements for Teachers and Guidance Counselors Lack Mandatory School-to-Work Training."
 

Under the STWOA, States are required to provide evidence of STW training and technical assistance for teachers, mentors, and counselors. However, there is nothing in the legislation to suggest STW training must be mandated as part of the State's certification requirements. Consistent with its history of strong local control, Iowa does not mandate any pre-service or inservice professional development requirements for teachers and guidance counselors. Again, this finding does not represent a strategy addressed in the State's plan. Additionally, the State does offer a variety of STW professional development activities through its Area Education Agencies (AEA). For example, we understand over 5000 Iowa teachers have participated in STW professional development opportunities through State-level Institutes, conferences, and other career development activities. Accordingly, we believe the State is making adequate efforts in this area. Further, our position remains that these are actions that fall exclusively within the State's domain, not the federal govemment's.
 

Finding No. 3: "The Development of Iowa's Integrated Information System (IIS) Needs to be Expedited."
 

We agree with DOL OIG that the timely implementation of a sound data management system is an important component in the evaluation, accountability, and continuous improvement of STW

We hope our comments provide sufficient detail to contribute to the proper revision of these matters. We believe these changes need to be addressed in the final report, if it is to serve as a useful resource for the State of Iowa and other States working towards strengthening the sustainability of their STW initiatives. Please let me know how I can be of further assistance.
 

Attachment

August 11, 1998   Mr. Gary B. Beggan Assistant Regional Inspector General for Audit U.S. Department of Labor Office of Inspector General 230 South Dearborn Street Chicago, IL 60604   Dear Mr. Beggan: The Iowa School-to-Work Administrative Team and I have thoroughly reviewed your draft report. We appreciate the time your staff took in working to understand our system in Iowa. Although we may agree in concept that your recommendations are pieces that could help build an even deeper sustaining element for Iowa, the notion of having the Assistant Secretary for Employment and Training collaborate with the Department of Education and the Iowa School-to-Work Administrative Team seems to be in conflict with Iowa's local control structure. To illustrate the point: The State of Iowa does not mandate any graduation requirements for local school districts. They are established at the local community and district level. If we supported the U.S. Department of Labor stepping to "collaborate" with the State on establishing a graduation prerequisite, we would only aid in promoting the current fear that the Federal and State governments desire to eliminate local control. Iowa is strongly a local-control state; and although at the State level develop suggested standards (i.e., Tier I & II) and recommend their use, we will not establish mandates. The following are our specific responses to each of your recommendations: 1. Establish student attainment in all STW components (i.e., school-based learning, work-based learning, and connecting activities) as an Iowa high school graduation prerequisite. Response: The State STW Office and the STW Administrative Team support and encourage local districts and communities to review their existing graduation requirements and determine if they support the goals and outcomes they have identified for their STW systems. We will continue to provide technical assistance in developing measurable outcomes and the relationship to graduation requirements; however, as mentioned earlier, the State of Iowa will not mandate graduation criteria. That is, by Iowa Code, a local education and community decision.

A PARTNERSHIP OF THE IOWA DEPARTMENTS OF ECONOMIC DEVELOPMENT, EDUCATION, AND IOWA WORKFORCE DEVELOPMENT, ABI, IOWA PTA, AND SOUTH CENTRAL IOWA FEDERATION OF LABOR AFL-CIO
 

2) Incorporate STW-related training into State certification requirements to make certain that teachers and guidance counselors are properly trained and have acquired the necessary skills.

Response:   We would like to address this question from two perspectives, one as teachers currently employed, and the other as certification requirements for new teachers.

• The Area Education Agencies (AEA) in Iowa are responsible for providing professional development for teachers currently employed. All professional development opportunities are to be developed based upon a needs assessment conducted by the AEA. In addition, teachers and guidance counselors receive credit for STW activity presentations at all STW related conferences. Based on our review of regional-level professional development activities, 14 of the 15 regions are currently providing professional development activities for teachers and guidance counselors throughout the year. This would indicate to the State that without mandate, local school districts are requesting STW-related training from their AEAs.

• The STW Administrative Team, representing the Departments of Education, Economic Development, and Workforce Development will submit a recommendation to the State of Iowa Board of Educational Examiners indicating that serious consideration be given to adding STW-related training into the State certification criteria. We will also provide supports for this recommendation based upon the amount of current professional development taking place at the local level through the AEAs, and feedback by local districts regarding the lack of readiness of new teachers entering systems engaged in School Improvement and STW elements.

Please note that the Iowa Department of Education does not have authority over the Board of Examiners, nor does Iowa Code provide for the Department to require certification elements. We do support your recommendation and will approach the Board of Examiners regarding this issue; however, as mentioned earlier, this is a State-level responsibility. We believe that the involvement from the Assistant Secretary for Employment and Training would only raise levels of concern.

Response: The timeline for the IIS full implementation laid out for the OIG auditors during their review involved many elements of a larger system than the one envisioned in 1993. The basic core of the system is nearly complete now; however, other elements such as the addition on Making Connections, and the data warehouse may take until the year 2000 to complete. In summary, the State believes we are moving as quickly as possible in assuring a thorough and quality-driven IIS product.

As an FYI: The Making Connections System will be active on the new system as early as November 1998. We encourage your review and feedback of this statewide resource.

Again, thank you for your in-depth review of the Iowa School-to-Work Initiative. We agree that we are building on a solid structure that will sustain the elements of STW long after the Federal funds are gone. On behalf of the STW Administrative Team, we appreciate your recommendations and trust you will contact us if you have any concerns or questions regarding our responses.
 

Sincerely,

Laurie C. Phelan
Director, Iowa School-to-Work Office

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