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11.23 Data Validation

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11.23.1 Background

Effective date: June 16, 2022

The U.S. Departments of Labor and Education released TEGL 7-18, Guidance for Validating Jointly Required Performance Data Submitted under the Workforce Innovation and Opportunity Act (WIOA) on December 19, 2018 and TEGL 23-19, Guidance for Validating Required Performance Data Submitted by Grant Recipients of U.S. Department of Labor (DOL) Workforce Programs on June 18, 2020. These provide federal guidance about how states must establish procedures to ensure the information contained in the reports is valid and reliable.1 DWD-DET's vision is to leverage this process to identify data issues at the soonest possible time to ensure data is corrected prior to report submission and further avoid inaccurate performance reporting. This policy and procedure outlines how Wisconsin's WIOA Title I and Title III programs ensure reported data are valid and reliable.


11.23.2 Applicability

Effective date: June 16, 2022

The following programs are subject to the data validation procedures established by DWD-DET:

  • WIOA Title I Adult
  • WIOA Title I Dislocated Worker
  • WIOA Title I Youth
  • National Dislocated Worker Grants
  • WIOA Title III Wagner-Peyser Employment Services

11.23.3 Procedures

Effective date: June 16, 2022

DWD-DET will review source documents against Automated System Support for Employment Training (ASSET) and Participant Individual Report Layout (PIRL) entries for Title I and Title III in accordance with the data elements outlined in TEGL 7-18, Attachment I and TEGL 23-19, Attachment II. DWD-DET will conduct technical reviews of the PIRL to ensure data transformation procedures are valid and reliable.

The sample selected for review must include a mixture of cases at various stages of the Universal Career Planning Process. The sample must include:

  • Participants in Education or Training during the previous quarter;
  • Active participants in the previous quarter;
  • Participant exits in the previous quarter (1 quarter lag);
  • Participant exits in the previous 4 quarters (2-4 quarter lag);
  • Participants with a credential (active or up to 7 quarter lag); and
  • Participants with a measurable skill gain (active within last quarter).

Data validation will include a review of required source documentation as outlined in Data Validation by Element. To ensure automated wage matching is valid, DWD-DET will compare ASSET information with UI wage data.

Data validation will include what occurs during annual onsite/virtual monitoring file review and periodic desk review. Separate Technical Assistance will be performed on data validation findings and trainings will be conducted on common issues and best practices.

DWD-DET will conduct a technical review of the PIRL prior to submitting the PIRL each quarter.


11.23.4 Responsibilities

Effective date: June 16, 2022

The following entities have responsibilities in the administration of Title I and III data validation efforts.

WIOA Performance Advisory Committee:

  • Provide overall guidance and technical assistance for data validation standards in accordance with federal guidance;
  • Oversee technical review of the PIRL and ASSET to ensure federal reports are properly completed;
  • Notify DET-Information Technology Coordination Section (ITSC) of any ASSET to PIRL data translation deficiencies;
  • Lead technical assistance, training development, and training delivery efforts; and
  • Design an annual assessment of the data validation procedures.

Local Program Liaison(s):

  • Conduct data validation for the Title I and III programs;
  • Document errors for correction during the data validation process;
  • Provide on-site technical assistance for field staff; and
  • Develop a procedure for determining the sample and the data validation results.

Local WDB Staff:

  • Develop internal controls to ensure data reported into ASSET is valid and reliable in accordance with this policy. Internal controls may include conducting routine case reviews, reviewing reports from the JCS-RED Data Warehouse, or any other activity that identifies incorrect data and implements corrections;
  • Ensure appropriate staff receive data validation training annually;
  • Correct identified data validation errors during quarterly reviews; and
  • Ensure that state monitoring staff have access to source documents for review upon notification.

Local Job Service Staff:

  • Develop internal controls to ensure data reported into ASSET are valid and reliable in accordance with this policy. Internal controls may include conducting routine case reviews, reviewing reports from the JCS-RED Data Warehouse, or any other activity that identifies incorrect data and implements corrections;
  • Ensure appropriate staff receive data validation training annually;
  • Correct identified data validation errors during quarterly reviews; and
  • Ensure state monitoring staff have access to source documents for review upon notification.

11.23.5 Training

Effective date: June 16, 2022

BWT will offer annual data validation training each program year for local WDB and Job Service staff. Training initiatives may include providing further clarifications in TEGL 23-19.


11.23.6 Compliance

Effective date: June 16, 2022

Failure to comply with identified corrective actions by the identified completion date may cause:

  • PIRL revisions by DWD-DET staff;
  • Mandatory on-site facilitated training by the LPL on the required reporting for data elements;
  • Issue of a monitoring "Finding";
  • Notification to the Division of Employment Training Administrator, Bureau of Job Service Director for possible administrative actions; and
  • Formal notification to the WDB Chair/Chief Elected Officer (CEO) of failure to comply.

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