Comments Received for High School Equivalency Subsidies ...
Comments Received for High School Equivalency Subsidies (House Bill 3) and Performance-Based Funding (House Bill 1949) Policy Concept Comment 1From: Louis D. MartinezTo: TWCPolicyCommentsCc: Honold, Eduardo A - Tea-Grant Compliance Spec, Community Education Services; Fraga, Anthony J - DirectorCommunity Services, Community Education Services; argonza1@Subject: RE: Far West Adult Education Consortium CommentsDate: Tuesday, April 07, 2020 2:35:35 PMRegarding Texas Workforce Commission High School Equivalency Subsidies (House Bill 3) andPerformance-Based Funding (House Bill 1949) Policy Concept:In page 4 lines 15-16 it is stated that the AEL programs are charged with “confirming the eligibility” of the subsidy recipient.? What is the burden of documentation for this procedure for non-AEL students.? What documents will be used to determine their eligibility and are they supposed to be stored for monitoring purposes.?? Another potential source of concern is the liability that programs might have for subsidy recipients who attempt to receive the benefit again using a different name and perhaps different documentation.? Will TWC have safeguards in place to prevent this from happening or will the burden fall exclusively on the AEL grantees?In the same section, AEL programs are supposed to determine the subsidy recipient’s “preparedness”? for the HSE test without further elaboration or clarification.? In the absence of even minimal guidelines should the rules assure programs that they will not be held responsible for a large number failed tests by subsidy recipients.Finally,? TWC will only release a portion of available subsidy funds to grantees and the rest after midyear, presumably based on the rate of utilization of the funds.? Most AEL programs have the bulk of their HSE test takers in the Spring as preparation for the test often exceeds a semester.? Is it possible that a mid-year evaluation of subsidy funds spent may underreport the true demand for the subsidy?Louis D. MartinezOn behalf of Far West Adult Education Consortium(915) 434-9401lmartinez29@Comment 2From:Juan C. Aguirre <jcaguirr@southtexascollege.edu>Sent:Wednesday, April 29, 2020 4:50 PMTo:TWCPolicyCommentsCc:ryan.guillen@house.; Eli Labrado; Dr. Shirley A. Reed; Rose BenavidezSubject:Public comments on policy concept (Chapter 800) - REVISEDTO: Texas Workforce CommissionFROM: Juan Carlos Aguirre, South Texas CollegeDATE: April 29, 2020SUBJECT: Public comment on policy concept regarding Chapter 800 rulesPlease accept my comments on the policy concept regarding performance-based funding as it relates to HB 1949 and TWC Chapter 800 General Administration Rules relating to Adult Education and Literacy (AEL). These comments supersede those submitted earlier today. I believe the true legislative intent of HB 1949 was to tie the proposed criteria (outlined in item 2 below) to federal, state, EL-Civics and TANF funding, not to performance incentive funding, which is intended to reward those entities demonstrating exemplary performance with respect to the proposed criteria. Proposed criteria should be moved from Labor Code section 315.007 to section 315.006, thereby holding AEL training providers that receive federal, state, EL-Civics, and TANF funding (not performance incentive funding) accountable for:The enrollment in a high school equivalency (HSE) program or a postsecondary ability to benefit program of at least 25% of all students receiving adult education and literacy services from the entity during that program year, andThe achievement by the end of that program year of a high school equivalency certificate or a postsecondary certificate by at least 70% of those students who exit the entity’s adult education program during that program year and who are enrolled in a high school equivalency program or a postsecondary ability to benefit program.Proposed criteria should be added to TWC rule 800.68 not as part of incentive or performance-based funding, but as a general requirement of training providers receiving federal, state, EL-Civics, and TANF funding. This would help alleviate the dire situation that plagues not only our region but the entire state. The following is the crisis in our area, which I believe is pervasive throughout Texas:In Hidalgo and Starr, the two counties that the college serves, there are about 206,000 people over age 18 without a high school diploma or its equivalent; of these, approximately 118,000 have less than a ninth-grade education. These individuals live below the poverty level, are either unemployed or underemployed, and are not able to enter college and pursue a certificate or degree –simply because they lack their high school diploma or its equivalent. The HSE certificate opens two very important doors for these folks: employment and Pell grant. Without the HSE certificate, they cannot enter college and apply for federal financial aid; without the HSE certificate, most of them cannot even apply for minimum-wage jobs.? Through individual and collective efforts in Hidalgo and Starr counties, on average only 500 HSE certificates are issued annually, a dismal number compared to the hundreds of thousands in need of this credential. Approximately $3 million of AEL funding comes to Starr, Hidalgo and Willacy counties every year but produces an average of 80 HSE certificates in the same time period. It is imperative that we increase accountability in terms of HSE completions.If our regional training provider were to be held accountable for the two proposed criteria, theyWould enroll at least 25% of 4,400 students (or 1,100) in an HSE program or a postsecondary ability to benefit program.Would work with these 1,100 students so that at least 70% (or 770) would earn an HSE certificate or a postsecondary certificate -compare 770 to 80!To match HB 1949 and Labor Code language, revise proposed performance benchmark (g) (1) (B) by changing “recognized postsecondary credential” to “recognized postsecondary certificate.”To match HB 1949 and Labor Code language, revise proposed definition of postsecondary ability-to-benefit program by changing “postsecondary education or training program” to “postsecondary certificate program.”“results in a recognized postsecondary credential” to “results in a recognized postsecondary certificate.”Thank you for considering this request, and thank you in advance for your diligent effort to right wrongs that have mired our region for decades.Juan Carlos AguirreSouth Texas College ................
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