11.23 Data Validation

Effective date: October 4, 2019

11.23.1 Background

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. This provides 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

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

The Bureau of Workforce Training (BWT) within DWD-DET holds primary responsibility for executing the Title I and III data validation procedures.

BWT 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. BWT 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).

BWT will conduct data validation activities during annual on-site monitoring and quarterly desk reviews. BWT will conduct a technical review of the PIRL prior to submitting the PIRL each quarter.

11.23.4 Responsibilities

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 Reporting and Frequency

The Local Program Liaisons (LPLs) will conduct the data validation report during the annual on-site monitoring visit and document the results in the local area's Consolidated Monitoring Report. Any documented deficiencies will be recorded with a date required for rectification consistent with the current monitoring correction timelines.

The LPLs will also conduct quarterly desk reviews. BWT will provide official results of the reviews to the local WDBs and local Job Service Directors. Reports will indicate required corrective actions. LPLs will determine the required completion date for corrections consistent with the impacted data's utility in performance indicators.

11.23.6 Training

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 7-18, Attachment I, Source Documentation for WIOA Core Programs.

11.23.7 Compliance

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

One year after the initial identification:
- PIRL revisions by DWD-DET staff; and
- Mandatory on-site facilitated training by the LPL on the required reporting for data elements.
Two years of high or repeated error rates:²
- 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.

¹ WIOA Sec. 116(d)(5)
² DWD-DET will define "high error rate" following completion of a baseline period. The definition will be published in a future update to this policy.

11.23 Data Validation