On June 12, 2015, the National Urban League submitted comments to the U.S. Department of Labor (DOL) and the U.S. Department of Education (ED) on two Notices of Proposed Rulemaking (NPRMs), each of which addressed different aspects of the implementation of the Workforce Innovation and Opportunity Act (WIOA) that was signed into law in July 2014. The proposed regulations represent a key milestone in WIOA implementation, and the Departments will be analyzing all the public comments and anticipate issuing Final Rules implementing WIOA in early 2016.
In both national public policy and in direct service delivery through its Urban League community-based affiliates, the National Urban League has always placed key emphasis on targeting Americans most in need, having multiple barriers to employment, through concrete steps to reach low-income unskilled and low-skilled adults and youth, including out-of-school youth, who have little attachment to the labor force, including low income older workers. The National Urban League finds that, unlike previous law (the Workforce Investment Act or WIA) WIOA overall greatly improves our workforce development system’s ability to respond to Americans most in need of its services by instituting a priority of service emphasis, increasing the role of community-based organizations throughout the system, and strengthening conflict of interest provisions at the State and Local levels. The NPRMs released by the Departments in April 2015 are a critical step towards these improvements, and throughout our comments we note areas where we are in support of the draft rules, as well as areas where we believe additional regulatory clarification or guidance may be needed.