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MEMO:  AP 06-10

Last Updated: June 25, 2018

DATE: April 24, 2006 

TO: WIB Directors; WIB Chairpersons; Grant Recipients

FROM: Carl Buzzelli, WIA Program Manager

SUBJECT:  Literacy and Numeracy Testing of Workforce Investment Act (WIA) Youth Participants

America's Workforce Network


  1. To issue procedures for implementing the Literacy and Numeracy Gains common measure for out-of-school youth; and

  2. To issue procedures for basic skills testing of all WIA Youth program participants.


Workforce Investment Boards (WIBs) are held to the 17 WIA performance measures established by the Workforce Investment Act of 1998.  Seven of these measures are applicable to youth.  These measures are: 

  • Older Youth, Entered Employment

  • Older Youth, Employment Retention Rate

  • Older Youth, Average Earnings Change

  • Older Youth, Credential/Certificate Rate

  • Younger Youth, Skill Attainment

  • Younger Youth, Diploma or Equivalent

  • Younger Youth, Retention

These performance measures remain in effect pending WIA reauthorization.

All states were required to implement common measures of WIA performance by July 1, 2005 with the exception of the literacy and numeracy measure for youth.  The two youth common measures effective as of July 1, 2005 are: 

  • Placement in Employment or Education

  • Attainment of a Degree or Certificate

Federal requirements mandate that the third youth common measure, Literacy and Numeracy Gains, be implemented no later than July 1, 2006.  Connecticut has chosen to implement this measure on this date.  Success in the literacy and numeracy measure is based upon an increase in the educational functioning level of out-of-school youth who are basic skills deficient.   

The methodology for showing an increase in this measure is as follows:  

Of those out-of-school youth who are basic skills deficient:  The number of youth participants who increase one or more educational functioning levels divided by the number of youth participants who have completed a year in the program (i.e., one year from the date of the first WIA youth program service) plus the number of youth participants who exit before completing a year in the youth program.    

Testing must be conducted with a tool that is compatible with the U.S. Department of Education’s National Reporting System (NRS).  This necessitates changes to the current testing method.  Using the Connecticut Competency System (CCS), youth will be given an appraisal (placement) test.  If the youth is found to be basic skills deficient in reading or math, an assessment pre-test is given in that area.  The youth is post-tested in that area at a later time.   

Although in-school youth are not included in this measure, it is the expectation of the U.S. Department of Labor that the educational functioning level of all youth be reviewed under WIA.  


  1. Basic Skills Deficient” Definition

    1. The U.S. Department of Labor defines “basic skills deficient” as follows: 

      The individual computes or solves problems, reads, writes, or speaks English at or below the eight grade level or is unable to compute or solve problems, read, write, or speak English at a level necessary to function on the job, in the individual’s family, or in society. 

      For the purpose of WIA administration in Connecticut, “basic skills deficient” is defined as scoring below 236 in reading and/or math on a Connecticut Competency System assessment instrument.

  2. Testing Tools

    1. The Connecticut Competency System tools will be used for appraisal, pre and post testing of youth.  Alternate tools may be used for youth with disabilities if appropriate. 

    2. The WIBs and/or their designees will use the Employability Competency System (ECS) series unless circumstances indicate that another series is more appropriate for an individual.   

  3. Appraisal 

    1. Effective July 1, 2006, all out-of-school youth entering the WIA program will be given an appraisal test, the ECS 130, for reading and math. 

    2. In-school youth may be appraised at the WIB’s discretion.  

  4. Assessment Pre-Testing 

    For all out-of-school youth entering the WIA youth program on or after July 1, 2006: 

    1. Assessment pre-testing is not required for those youth who score 236 or higher in both reading and math on the appraisal (ECS 130).

    2. Youth who score below 236 in reading and/or math on the appraisal must be assessed with an ECS pre-test. 

    3. The selection of the ECS pre-test version is determined by the youth’s appraisal score.

    4. Youth are pre-tested in the area, or areas, in which the appraisal score was below 236.  If the youth scored below 236 in both reading and math, the youth is assessed with a pre-test in both reading and math.  If the youth scored below 236 in either reading or math, the youth is assessed with a pre-test in that specific area. 

    5. The assessment pre-test is administered within sixty days of the date of the first WIA youth program service.  It is given as soon as possible after the appraisal, prior to the occurrence of any substantial instructional intervention.  Substantial instructional intervention is instruction that one would reasonably expect to affect test results. 

    6. If an out-of-school youth scores 236 or higher in both the reading and math pre-test, the youth is not considered basic skills deficient, regardless of the appraisal scores.  This youth is not included in the literacy and numeracy measure.   

    7. WIBs, at their discretion, may administer assessment pre-testing to in-school youth.  

      Once WIA eligibility is established, eligibility does not change even if a determining factor changes.  If a youth was determined to be basic skills deficient based on the ECS 130 appraisal, but then pre-tested at a level of basic skill proficiency (236 or higher), his or her eligibility is not affected.

  5. Assessment Post-Testing

    For all out-of-school youth entering the WIA youth program on or after July 1, 2006:  

    1. Post-tests are administered until the youth scores 236 or higher in both reading and math, or until the youth exits the program.

    2. The initial post-test must be administered within one calendar year of the date of the first WIA youth program service.

    3. Second year post-testing and instruction must be administered prior to the second anniversary date of the first WIA youth services.  Subsequent year post-tests and instruction must be administered prior to that year’s anniversary date of the first WIA youth service.

    4. The initial post-test version must be in the same series as the pre-test.

    5. The ECS test form number of each subsequent post-test must be different from the form number of the last taken test.  The form may or may not be in the same scoring range dependent upon the score of the last taken test.

    6. Under common measures, to achieve a positive outcome in the literacy and numeracy measure, an out-of-school youth must demonstrate an increase of one educational functioning level in either reading or math during the measurement period.

  6. Accepting Test Results from Outside Entities

    1. The WIBs will accept CCS test scores from adult education for the purposes of determining pre-test selection and/or as a pre-test score provided that:

      • There has not been substantial instructional intervention; and

      • Test results are no more than 180 days old.  While test results that are no more than 180 days old may be accepted, it is recommended that test results be limited to those that are no more than 90 days old.

    2. The WIBs will accept CCS test scores from adult education for the purpose of determining WIA eligibility provided that: 

      • There has not been substantial instructional intervention; and

      • Test results are no more than 90 days old. 

    3. The WIBs, at their discretion, may accept CCS test scores from organizations and agencies other than adult education provided that the conditions regarding substantial instructional intervention and age of test results as noted in Item VII.A and/or Item VII.B are met.   

    4. CCS test scores from any series (that is, Life Skills, Employability Competency System -  ECS, Workforce Learning Systems - WLS, Life and Work - LW, Citizenship) may be accepted.

    5. Release authorizations, signed by the student, or legal guardian if appropriate, must accompany test results coming from adult education or any other organization.

  7. Testing Youth Who Enrolled in WIA Prior to July 1, 2006 (Carry-over Youth)

    1. Carry-over youth, that is youth in WIA prior to July 1, 2006, are pre and post-tested using testing procedures in place prior to July 1, 2006.  These testing procedures are maintained for these youth for the duration of their participation in WIA youth programming.  These youth must attain a 5-point increase under these testing procedures to demonstrate an educational increase under the Skill Attainment measure.

  8. Testing Youth with Special Needs and/or Disabilities

    1. WIBs are responsible for providing reasonable accommodations when testing youth with documented disabilities.

      Accommodations in testing alter the conditions for administering a test or change the nature of an instrument allowing test-takers with disabilities to demonstrate more accurately their skills and abilities.  Proper accommodations meet the needs of examinees without changing what a test is intended to measure.  Accommodations may be similar to “test-taking strategies” such as requesting to take only one test per day, testing in an alternate quiet room or taking frequent breaks.  Test-takers may also use a variety of aides when taking a test, such as using a plain straight-edge ruler, a different type of answer sheet, magnifying strips, colored overlays, ear plugs, or other devices as deemed appropriate.  It is not an appropriate accommodation to read a reading test to a test-taker with low literacy skills or blindness.  The purpose of a reading test is to assess reading skill levels and to determine the test-taker’s appropriate instructional level, not to assess knowledge of a subject area.  [Note: Taken from CCS Assessment Policies and Guidelines, p.13]

    2. When administering appraisal and assessment tools, individuals with disabilities are to be provided with reasonable accommodations, as appropriate, according to:

      1. Section 188 of the Workforce Investment Act (implementing regulation at 29 CFR Part 37), Section 504 of the Rehabilitation Act of 1973 (DOL implementing regulations at 29 CFR Part 32), and Title II of the Americans with Disabilities Act, if applicable, (implementing regulations at 28 CFR 35) taking into consideration;

      2. Guidelines associated with the appraisal and assessment tools; and

      3. State laws and/or policy.

        Regulations implementing WIA Section 188, found at 29 CFR Part 37, provide a general definition of “reasonable accommodation” for individuals with disabilities.  In essence, such accommodations are modifications or adjustments, made on a case-by-case basis, “that enable a qualified individual with a disability . . . to receive aid, benefits, services, or training equal to that provided to qualified individuals without disabilities.”  (See 29 CFR Part 37.4, definition of “reasonable accommodation”)  In the appraisal and assessment context, therefore, accommodations are changes that are made to the materials or procedures used for the assessment in order to “level the playing field” to ensure that the assessment tool measures the individual's skills and abilities, and not his or her disabilities.  Because youth with disabilities are expected to achieve the same gains as other youth, it is critically important that appropriate accommodations be provided for the assessment process, to ensure that the gains achieved by these youth can be determined accurately.

        Accommodations for the assessment process generally fall into the following categories:

        • Changes to the methods of presentation of the tool used as appraisal or assessment tool:  e.g., providing Braille versions of the test, or orally reading the directions or test questions to test-takers, 

        • Changes to the methods or response to the test questions: e.g., having the test-taker point to a response or use a computer for responding,

        • Changes to the setting in which the test is provided: e.g., permitting the test to be taken at home, or in small groups, rather than in a large-group or institutional setting; and

        • Changes to the timing/scheduling of the test: e.g., extending the amount of time generally provided for completion of the test, permitting frequent breaks.

        The Employment and Training Administration (ETA) of the U.S. Department of Labor fully expects that most youth with disabilities can, and should, be assessed using tests that specifically crosswalk to educational functioning levels, using accommodations where needed.  ETA also recognizes that in very limited instances, use of these testing instruments, even with appropriate accommodations, may not provide a valid or reliable evaluation of the literacy and numeracy skills of a youth with one or more disabilities.  These instances may arise because of the nature or extent of a particular individual’s disability, and/or because of limitations in the testing instruments themselves.

    3. Testing accommodations must be consistent with the disability documentation.  Test-takers are responsible for providing documentation of the disability.  Decisions regarding accommodations are made on a case-by-case basis.  [CCS, pp. 13, 14]

  9. Test Administration

    1. WIBs must designate a WIB CCS Program Facilitator who is trained by the State Department of Education in CCS test administration.  The Facilitator will be responsible for testing and/or for training test facilitators.  The Facilitator must complete CCS Training Part 1 (Appraisals) and Part 2 (Survey Achievement Pre and Post Assessments). 

    2. WIBs must maintain a current Test Security Agreement which outlines the requirements relative to the secure storage and handling of all CCS materials.  A signed Test Security Agreement must be filed with Adult Training and Development Network (ATDN) division of CREC or other entity designated by the Connecticut State Department of Education.

  10. Performance Adjustment

    1. The U.S. Department of Labor and the Connecticut Department of Labor acknowledge that the nature of some disabilities, such as severe cognitive impairment, may preclude meaningful literacy and numeracy testing and consequent attainment of the literary and numeracy common measure goal.  It is not the intent of the federal and state Departments of Labor to discourage WIA participation by individuals with these circumstances.  In order to foster WIA program development for individuals with such circumstances, WIBs may request one of two adjustment methods:

      • Service to individuals with such circumstances can be addressed in annual WIA performance negotiations.  In effect, negotiated target performance would be adjusted from expected levels so that a WIB would not be penalized for serving individuals who may not reasonably be expected to attain a positive outcome in a performance measure, specifically the measures for attainment of a degree or certificate or an increase in literacy and numeracy.


      • WIBs can request a performance adjustment at the end of the program year being measured.  As part of such a request, WIBs must demonstrate that the inclusion of individuals with such circumstances negatively impacted performance


  • “Connecticut Competency System (CCS), Assessment Policies and Guidelines, Fiscal Year 2005 - 2006,” Connecticut State Department of Education, Bureau of Early Childhood, Career and Adult Education, September 2005.

  • “Training and Employment Guidance Letter No. 17-05, Subject: Common Measures Policy for the Employment and Training Administration’s (ETA) Performance Accountability System and Related Performance Issues,” U.S. Department of Labor, Employment and Training Administration, February 17, 2006.

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