oversight

Trade Adjustment Assistance: Labor Awarded Community College Grants in Accordance with Requirements, but Needs to Improve Its Process

Published by the Government Accountability Office on 2012-09-28.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States Government Accountability Office

GAO              Report to Congressional Committees




September 2012
                 TRADE
                 ADJUSTMENT
                 ASSISTANCE
                 Labor Awarded
                 Community College
                 Grants in Accordance
                 with Requirements,
                 but Needs to Improve
                 Its Process




GAO-12-954
                                             September 2012

                                             TRADE ADJUSTMENT ASSISTANCE
                                             Labor Awarded Community College Grants in
                                             Accordance with Requirements, but Needs to
Highlights of GAO-12-954, a report to        Improve Its Process
congressional committees




Why GAO Did This Study                       What GAO Found
The Trade and Globalization                  The Department of Labor (Labor) designed and awarded the grants following its
Adjustment Assistance Act of 2009            standard competitive award process by developing and publishing an
(TGAAA), part of the American                announcement, screening applicants, and convening expert panels to score
Recovery and Reinvestment Act of             applications. It also collaborated with the Department of Education to develop the
2009, authorized assistance to               announcement and identify panelists. Though they varied in terms of target
communities, workers, farmers, and           populations, as permitted by the grant, the applications GAO reviewed addressed
firms affected by trade. One such            trade impact, as required. However, the law’s requirement that every state
program, the Trade Adjustment                receive a minimum amount of funding created challenges for Labor and certain
Assistance Community College and
                                             grantees when applicants in 17 states scored below the cutoff score for grant
Career Training grant program, is
                                             awards. In these instances, Labor’s process stipulated that states designate an
administered by Labor and authorizes
grants to eligible institutions of higher
                                             eligible institution. States, however, were given a 3-day deadline—over a
education for educational or career          weekend—to designate a grantee. As a result, these states had little time to
training programs suitable for trade-        identify an institution. The states that GAO contacted said that they found this
affected workers. Total grant funding is     process challenging or confusing and that they received no guidance from Labor.
$2 billion for 4 years and the first round   Moreover, state-designated grantees experienced delays in implementing their
of grants was awarded in September           grants and required assistance from Labor to modify their original proposals and
2011. The TGAAA requires GAO to              comply with grant requirements. Labor has identified lessons learned from the
examine the operation and                    first round of grants and applied them to the second round, but the process for
effectiveness of the changes made by         selecting state-designated grantees has remained similar to that used in the first
the act to this program. GAO examined        round.
how Labor (1) designed and awarded
the grants and to what extent it             Labor monitors grantees in various ways and grantees are in the early stages of
complied with applicable requirements;       implementation. Most grantees, as anticipated, are building capacity for their
(2) monitors the grants and what is          programs and have not yet enrolled participants. Labor reviews grantees'
known about implementation to date;          quarterly progress reports, communicates with grantees, and plans to conduct
and (3) plans to evaluate the program.       on-site monitoring as resources permit. The most recently available progress
GAO reviewed a nongeneralizable              reports indicate that grantees have taken steps to set up their programs by, for
sample of 32 grant applications based        example, hiring program administrators and developing curricula. In addition, as
on funding status, total scores, and         of March 31, 2012, grantees had spent 5 percent of awarded funds, but have
total grant amounts; grantees’ quarterly     until September 2014 to spend all the funds. State-designated grantees received
reports; and relevant federal laws,          funds several quarters after the grants were awarded, while awaiting Labor's
regulations, policy and guidance; and        approval of their plans, but Labor’s monitoring did not indicate that these grants
interviewed federal and state officials.     were more likely to have problems with grant integrity or performance than the
                                             others. Labor rated the overall risk of most grants as low, but identified
What GAO Recommends
                                             performance accountability as a moderate or high risk area for more than a third
GAO recommends that Labor take               of grants after the first quarter of fiscal year 2012. In response to this
steps to more effectively manage its         implementation challenge, Labor issued additional guidance for grantees.
process when states must designate
grantees by, for example, building in        Labor plans to evaluate the program at the national and grantee levels. Labor
additional lead time or providing states     plans to begin the first phase of the evaluation in fall 2012. Labor stated that the
with guidance to help inform their           evaluation will be based partly on a survey of grant recipients and site visits to a
designation of a grantee. Labor agreed       sample of grant projects. Given the relatively early stage of grant implementation,
with the recommendation.                     the national evaluation will focus on program implementation and subsequently
                                             examine outcome data to assess program effectiveness. Also, round-two
                                             grantees will be required to obtain third-party evaluations of their projects. Labor
                                             anticipates challenges in obtaining consistent and comparable grantee outcome
View GAO-12-954. For more information,
contact Andrew Sherrill at 202-512-7215 or   data. And given that the grant performance period for the first round of grants is 3
sherrilla@gao.gov                            years, it will likely be several more years before Labor can determine overall
                                             program effectiveness.

                                                                                      United States Government Accountability Office
Contents


Letter                                                                                           1
                       Background                                                                4
                       Labor Designed and Awarded Grants in Accordance with TGAAA
                         Requirements, but Found It Challenging to Award Each State a
                         Minimum Amount of Funding                                               8
                       Labor Is Tracking and Addressing Issues Raised by Grantees, and
                         Grant Implementation Is in an Early Stage                             20
                       Labor Plans to Evaluate the Program at the National and Grantee
                         Level, but Anticipates Some Challenges                                25
                       Conclusions                                                             26
                       Recommendation for Executive Action                                     27
                       Agency comments                                                         27

Appendix I             Grants Awarded in Round One and TAA Information by State                29



Appendix II            Comments from the Department of Labor                                   32



Appendix III           GAO Contacts and Staff Acknowledgments                                  33



Related GAO Products                                                                           34



Tables
                       Table 1: Evaluation Criteria of TAACCCT Round One Grant
                                Applications                                                     9
                       Table 2: Community College and Career Training Grants Awarded
                                in Round One                                                   12


Figures
                       Figure 1: Labor’s Competitive Grant Award Process                         7
                       Figure 2: Process for Reviewing and Scoring TAACCCT Grant
                                Applications                                                   13
                       Figure 3: Range of Scores and Median Scores for TAACCCT Round
                                One Applications                                               15



                       Page i                               GAO-12-954 TAA Community College Grants
Figure 4: Timeline of TAACCCT Grant Program for Round One of
         Grants                                                                           16
Figure 5: Labor’s Overall Risk Assessments by How Grantee was
         Selected, after First Quarter of Fiscal Year 2012                                23
Figure 6: Labor’s Risk Assessment of Grants by Risk Area, after
         First Quarter of Fiscal Year 2012                                                24




Abbreviations

Education                  Department of Education
Labor                      Department of Labor
SGA                        Solicitation for Grant Applications
TAA                        Trade Adjustment Assistance
TAACCCT                    Trade Adjustment Assistance Community College
                           and Career Training
TGAAA                      Trade and Globalization Adjustment Assistance Act
                           of 2009




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Page ii                                        GAO-12-954 TAA Community College Grants
United States Government Accountability Office
Washington, DC 20548




                                   September 28, 2012

                                   The Honorable Max Baucus
                                   Chairman
                                   The Honorable Orrin G. Hatch
                                   Ranking Member
                                   Committee on Finance
                                   United States Senate

                                   The Honorable Dave Camp
                                   Chairman
                                   The Honorable Sander Levin
                                   Ranking Member
                                   Committee on Ways and Means
                                   House of Representatives

                                   In an increasingly competitive global economy, America’s economic
                                   strength depends upon the education and skills of its workers. According
                                   to the Department of Labor, occupations that usually require a post-
                                   secondary degree are expected to account for nearly half of all new jobs
                                   from 2008 to 2018, and the fastest growth will occur in occupations
                                   requiring an associate’s degree. Community colleges, which award
                                   associate’s degrees and other credentials, are major contributors to the
                                   nation’s higher education system, enrolling more than 7 million students
                                   each year, or about 40 percent of all post-secondary students. 1

                                   The Trade Adjustment Assistance Community College and Career
                                   Training (TAACCCT) grant program was created to support educational
                                   and career-training programs suitable for workers who have lost their jobs
                                   or are threatened with job loss as a result of foreign trade. The TAACCCT
                                   program was authorized by the Trade and Globalization Adjustment
                                   Assistance Act of 2009 (TGAAA), which was part of the American
                                   Recovery and Reinvestment Act of 2009. 2 Under the TAACCCT grant



                                   1
                                    In 2008, we reported how community colleges meet workforce training needs. See GAO,
                                   Workforce Development: Community Colleges and One-Stop Centers Collaborate to Meet
                                   21st Century Workforce Needs, GAO-08-547 (Washington, D.C.: May 15, 2008).
                                   2
                                    Pub. L. No. 111-5, div. B, tit. I, subtitle I, § 1872(a), 123 Stat. 401, codified at 19 U.S.C.
                                   §2371. The TGAAA amended the Trade Act of 1974, Pub. L. No. 93-618.




                                   Page 1                                             GAO-12-954 TAA Community College Grants
program, the Department of Labor (Labor) awards grants to eligible
institutions of higher education 3—including consortia of two or more
institutions—to develop, offer, or improve educational or career training
programs for workers who are eligible for training under the Trade
Adjustment Assistance (TAA) for Workers program, which provides
federal assistance to workers who have been adversely affected by
foreign trade. 4 Congress appropriated $500 million per fiscal year from
2011 to 2014 to carry out the grants program. Each state, the District of
Columbia, and Puerto Rico is guaranteed a minimum of 0.5 percent of the
total funding, or $2.5 million per state per year. 5 While the statute assigns
Labor the responsibility of awarding and administering the grants, Labor
has implemented the grant in partnership with the Department of
Education (Education).

The first Solicitation for Grant Applications (SGA) was published in
January 2011 and the grant recipients were announced on September 26,
2011. The first round resulted in a total of 258 applicants and 49 winning
awards. The second SGA was published in February 2012 and the
application deadline was May 24, 2012. According to Labor officials,
Labor plans to announce the second round of winning grants no later than
September 30, 2012.




3
 For purposes of the TAACCCT grants, eligible institutions are institutions of higher
education eligible to participate in federal student aid programs authorized under Title IV
of the Higher Education Act of 1965, as amended, offering programs that can be
completed in 2 years or less, and include public, private non-profit, and for-profit
institutions. 19 U.S.C. § 2371(b)(1).
4
 While the grants are intended to assist institutions in developing, offering, or improving
training programs for TAA-eligible workers, other workers, such as dislocated and
unemployed workers, may enroll in these training programs.
5
 Health Care and Education Reconciliation Act of 2010, Pub. L. No. 111-152, § 1501, 124
Stat. 1070, codified at 19 U.S.C. § 2372(b).




Page 2                                           GAO-12-954 TAA Community College Grants
The TGAAA mandated that we report on the operation and effectiveness
of the amendments made by this Act no later than September 30, 2012. 6
Given that the first round of grants was recently awarded, this report
examines the processes that Labor followed in awarding, monitoring, and
developing plans to evaluate the first round of TAACCCT grants.
Accordingly, we addressed the following questions:

1. How did Labor design and award the grants and to what extent did it
   comply with applicable requirements?
2. How does Labor monitor the grants and what is known about
   implementation to date?
3. How does Labor plan to evaluate the program?
To determine how Labor designed and awarded the grants and the extent
to which it complied with applicable federal requirements, we reviewed
the 2009 legislation and other relevant federal laws, regulations, and
guidance; Labor’s policies and procedures; and TAACCCT grant
announcements and solicitations. We also interviewed Labor and
Education officials to obtain a better understanding of how the TAACCCT
grants were awarded. In addition, we reviewed a nongeneralizable
sample of 32 grant applications to determine if Labor complied with
applicable requirements in awarding the grants. Of the 49 grants
awarded, our sample included 9 grantees who were awarded a grant
through Labor’s standard grant award process, and all 17 grantees who
were awarded a grant based on designations by state higher education
agencies. In addition, our sample included 6 of the 211 applications that
were not awarded a grant. Our criteria for selecting the 9 funded and 6
unfunded applications included (1) grantees’ status as individual or
consortium grantees, (2) a range of total scores assigned through the



6
 The TAA programs provide assistance to farmers and fishermen, firms, workers, and
communities impacted by trade. See GAO, Trade Adjustment Assistance: Changes to the
Workers Program Benefited Participants, but Little Is Known about Outcomes,
GAO-12-953 (Washington, D.C.: September 28, 2012); GAO, Trade Adjustment
Assistance: USDA Has Enhanced Technical Assistance for Farmers and Fishermen, but
Steps Are Needed to Better Evaluate Program Effectiveness, GAO-12-731 (Washington,
D.C.: July 12, 2012); GAO, Trade Adjustment Assistance: Commerce Program Has
Helped Manufacturing and Services Firms, but Measures, Data and Funding Formula
Could Improve, GAO-12-930 (Washington, D.C.: September 13, 2012); and GAO, Trade
Adjustment Assistance: One-Time Grants Awarded to Trade-Impacted Communities;
Results Will Not Be Known until after 2013, GAO-12-993 (Washington, D.C.: September
26, 2012).




Page 3                                     GAO-12-954 TAA Community College Grants
             grant selection process, (3) a range of total grant amounts, (4) receipt of a
             supplemental award for certain purposes allowed by the grant, (5)
             number of trade-affected workers in each state, and (6) presence of a
             Department of Commerce grant to trade-affected communities.
             Additionally, to better understand how the grants were awarded and to
             determine how states designated grantees, we interviewed three
             grantees and representatives of four state higher education agencies
             selected based on a mix of factors including an applicant’s total score
             assigned through the grant selection process, whether the application
             went through the scoring process, and the number of applicants within a
             given state.

             To determine how Labor monitors the grants and what is known about
             grant implementation, we interviewed Labor officials about the agency’s
             monitoring systems and practices. We also reviewed grantees’ quarterly
             progress and financial reports, as well as Labor’s assessments of these
             reports. To determine how Labor plans to evaluate the program, we
             reviewed Labor’s progress and outcome measures for the program and
             its first annual report on the grants. We also interviewed Labor officials
             about their plans to conduct formal program evaluations.

             We conducted this performance audit from February 2012 through
             September 2012 in accordance with generally accepted government
             auditing standards. These standards require that we plan and perform the
             audit to obtain sufficient, appropriate evidence to provide a reasonable
             basis for our findings and conclusions based on our audit objectives. We
             believe that the evidence obtained provides a reasonable basis for our
             findings and conclusions based on our audit objectives.


             The TAA Community College and Career Training grant program is one
Background   of three grant programs that were included in the TAA for Communities
             Program when it was reestablished by the Trade and Globalization
             Adjustment Assistance Act of 2009 (TGAAA). 7 The other two grant
             programs—the Department of Commerce TAA for Communities Grant
             Program and Labor’s Industry or Sector Partnership Grant Program for
             Communities Impacted by Trade—were eliminated in 2011 by the TAA


             7
              The Trade Act of 1974 as originally enacted included provisions authorizing trade
             adjustment assistance for communities but included a provision terminating the program
             on September 30, 1982. Pub. L. No 93-618, § 284, 88 Stat. 2041.




             Page 4                                        GAO-12-954 TAA Community College Grants
Extension Act. 8 The 2011 legislation also expanded the types of data
required for Labor’s annual report on the TAACCCT program, including
the amount and duration of grants awarded and certain outcomes for TAA
recipients participating in activities funded under TAACCCT grants. 9

The TAACCCT grants allow community colleges and other eligible
institutions of higher education to develop, expand, and improve
education and training programs that can be completed in 2 years or less
and result in skills, degrees, and credentials that prepare program
participants for employment in high-wage, high-skill occupations. In
particular, according to Labor’s grant announcement, the program is
designed to fund projects that seek to use data and evidence to: (1)
design program strategies that are likely to produce positive learning and
employment outcomes for program participants, (2) continuously evaluate
the effectiveness of their strategies in order to improve their programs,
and (3) participate in evaluations that determine long-term program
impacts. Labor encourages partnership building by requiring applicants to
involve the public workforce system and at least one employer in forming
programs to help ensure that participants will be prepared with the skills
needed in the region.

In addition, Labor, in its SGA, required applicants to address one or more
of the following four priority areas, which reflect strategies to help trade-
affected workers overcome the primary barriers to labor market entry:

1. Accelerating progress for low-skilled and other workers;
2. Improving retention and achievement rates and/or reducing time to
   completion;
3. Building programs that meet industry needs, including developing
   career pathways; and


8
 The two grant programs were eliminated by section 222(a) of the Trade Adjustment
Assistance Extension Act of 2011, Pub. L. No. 112-40, tit. II, 125 Stat. 411. The
Department of Commerce TAA for Communities Grant Program was funded at $36.8
million in FY 2010, but no funds were appropriated in FY 2011. For more information on
the Department of Commerce’s TAA for Communities grant program, see GAO, Trade
Adjustment Assistance: One-Time Grants Awarded to Trade-Impacted Communities;
Results Will Not Be Known until after 2013, GAO-12-993 (Washington, D.C.: September
26, 2012). The Industry or Sector Partnership Grant Program was never funded by
Congress.
9
Pub. L. No. 112-40, § 222(b), 125 Stat. 411.




Page 5                                         GAO-12-954 TAA Community College Grants
                            4. Strengthening online and technology-enabled learning.
                            According to Labor, successful applicants from round one uniformly
                            addressed all four priority areas, and many applicants chose projects that
                            integrated a combination of the priority areas. Labor indicated that
                            applicants from round one covered a wide range of sectors including
                            healthcare, manufacturing, energy, information technology, engineering,
                            transportation, agriculture/food and natural resources, architecture,
                            biotechnology, business, environmental management, law
                            enforcement/public safety, and retail.


Labor’s Competitive Grant   Labor’s competitive grant award process consists of the following key
Award Process               steps, as illustrated in figure 1.

                            Grant Announcement: Labor begins the competition process by
                            publishing a “Solicitation for Grant Applications” (SGA) for each grant
                            program. The SGA describes the project to be funded, establishes
                            eligibility requirements, identifies the amounts to be awarded, and
                            instructs applicants on how to complete and submit the application. 10 The
                            SGA also includes criteria used to evaluate applications.

                            Application Pre-Screening: Applications are prescreened to determine
                            whether they meet specific requirements. Applications are eliminated
                            from review if they are received after the deadline or if they do not meet
                            all requirements.

                            Technical Review of Applications: Applications remaining after pre-
                            screening are submitted to technical review panels. Panels review and
                            score the applications using the criteria set forth in the SGA. The panel
                            assigns points to each application that are added up to derive the
                            applicant’s average score. The ranked scores serve as the primary basis
                            for selecting the applications to receive awards, although other criteria,
                            such as the availability of grant funds, may also be considered. Labor’s
                            grants management staff identify the cutoff score that separates
                            successful applicants from unsuccessful ones.




                            10
                              “Applying for ETA Grants: A Guide to the Competitive Process,” Department of Labor
                            (Washington, D.C.: n.d.).




                            Page 6                                       GAO-12-954 TAA Community College Grants
                                       Final Grant Award Decisions: Taking into account peer review panel
                                       scores and comments for each application and, in some cases, other
                                       factors, Labor’s grants management office makes the final award
                                       decision. These decisions are documented in the final funding award
                                       decision memos, which contain the list of applicants—ranked by scores—
                                       and the final award decisions.

                                       Notification of Award Decisions: Each applicant is sent a letter that
                                       communicates the grant award decision. All applicants may request
                                       feedback on the results of the review panel.

Figure 1: Labor’s Competitive Grant Award Process




                                       Page 7                                GAO-12-954 TAA Community College Grants
Labor Designed and
Awarded Grants in
Accordance with
TGAAA
Requirements, but
Found It Challenging
to Award Each State a
Minimum Amount of
Funding

Labor Designed Grants in   Labor’s design of the TAACCCT grants complied with federal
Accordance with TGAAA      requirements. The TGAAA required that Labor issue and publish
Requirements               guidelines for applicants, and that applicants’ proposals include detailed
                           project descriptions. 11 Labor’s SGA for the first round of TAACCCT grants
                           provided information about grant objectives and invited applicants to
                           describe their need for the grant, work plans, and expected outcomes. 12
                           The SGA assigned a maximum number of possible points to criteria to be
                           used in scoring the applications, as shown in table 1.




                           11
                                19 U.S.C. § 2371(c).
                           12
                            Notice of Availability of Funds and Solicitation for Grant Applications for Trade
                           Adjustment Assistance Community College and Career Training Grants Program, funding
                           opportunity number: SGA/DFA PY 10-03, January 21, 2011.




                           Page 8                                     GAO-12-954 TAA Community College Grants
Table 1: Evaluation Criteria of TAACCCT Round One Grant Applications

                                                                                              Maximum Number of
 Criterion                                                                                        Points Available
 Statement of Need                                                                                               30
  Impact of Foreign Trade in Communities to Be Served                                                            5
  Targeted Population in Communities to Be Served                                                                5
  Targeted Industries and Occupations                                                                            10
  Gaps in Existing Educational and Career Training Programs                                                      10
 Work Plan and Project Management                                                                                45
  Evidence-Based Design and Overview of Proposed Strategy                                                        15
  Project Work Plan                                                                                              15
  Project Management                                                                                             10
  Sustainability                                                                                                 5
 Measurement of Progress and Outcomes                                                                            25
  Progress and Implementation Measures                                                                           10
  Outcome Measures                                                                                               15
 Total Possible Points                                                                                          100
Source: U.S. Department of Labor, Employment and Training Administration, SGA/DFA PY 10-03, January 21, 2011.

Note: Labor made some changes in the criteria and maximum points for round two. The SGA for
round two allocates 20 points for the Statement of Need, 10 points of which are available for serving
the education and training needs of TAA-eligible workers, 5 for evidence of job opportunities in the
targeted industries and occupations, and 5 for gaps in existing education and training programs in the
community. Additionally, the SGA for round two allows 40 points for project description, including its
evidence basis; 20 for work plan and project management; and 20 for outcomes. See Notice of
Availability of Funds and Solicitation for Grant Applications for Trade Adjustment Assistance
Community College and Career Training Grants Program, SGA/DFA PY 11-08, February 27, 2012.


To develop the SGA, Labor incorporated the TGAAA’s requirement that
programs be suited for workers eligible for training under the TAA for
Workers program. Accordingly, the SGA stated that the target population
for the grant is workers who have lost their job or are threatened with job
loss as a result of foreign trade. However, the TGAAA did not specify
eligibility requirements for the workers to be served by these programs,
and the SGA acknowledged that grant-funded training programs could
serve other workers. 13



13
  According to Labor, eligible participants include TAA-eligible workers as well as other
individuals whom grantees deem eligible. However, TAA-eligible workers must be given
enrollment priority if the grantee must choose between two qualified candidates for
enrollment.




Page 9                                                            GAO-12-954 TAA Community College Grants
The grant applications we reviewed defined their target populations
differently. While virtually all focused on trade-affected workers, some
also included dislocated, 14 unemployed, and low-skilled workers and
jobseekers.

Additionally, consistent with TGAAA’s purpose of improving training
programs for workers impacted by trade, the SGA required applicants to
demonstrate trade impact in their communities. Virtually all the funded
applications we reviewed addressed trade impact, by citing TAA
certifications and in many cases associated estimates of affected
workers. 15

These two criteria—target population and trade impact—represented a
combined 10 out of 100 points. The applications that we reviewed scored
between 4.6 and 10 on these criteria.

Also, while not a requirement of TGAAA, the SGA also required
applicants to address the sustainability of their proposed programs. Our
review of funded applications shows that the majority addressed this
requirement by describing specific actions they planned to take. 16 For
example, some applicants proposed to sustain their programs beyond the
grant period through tuition revenue, and some identified other means,
such as new revenue from online learning programs, employer support,
and more efficient practices. Labor officials told us that they also
consulted with Education to conceptualize the grant design and that
Education reviewed and provided feedback on initial drafts of the SGA. 17




14
  As defined by the Workforce Investment Act of 1998, dislocated workers are those who
have been terminated or laid off, have received a notice of termination or layoff from
employment, are eligible for or have exhausted unemployment insurance, or who meet
certain other conditions. Pub. L. No. 105-220 § 101(9), codified at 19 U.S.C. § 2801(9).
15
   Under the TAA for Workers program, workers, unions, employers, or other parties may
file a petition with Labor on behalf of a group of workers for a determination of trade
impact and certification of eligibility to apply for trade adjustment assistance. 19 U.S.C.§
2271. In addition, applicants for TAACCCT grants could demonstrate impact of foreign
trade if the Secretary of Commerce has determined that the community served by the
institution is eligible to apply for assistance under the TAA for Communities program.
16
     Two of the grant files were incomplete at the time of our review.
17
  Education reviewed the SGA with particular regard to the design, priorities, and selection
criteria for grant awards, according to Education officials.




Page 10                                            GAO-12-954 TAA Community College Grants
                           In addition to publishing the SGA in the Federal Register, Labor
                           publicized the grant opportunity by holding a webinar in January 2011 to
                           alert prospective applicants and provide an overview of the grant
                           opportunity and the process for reviewing applications. Labor officials
                           noted that Education also performed outreach about the grant program.


Labor Followed Its         Labor followed its standard competitive grant award process to screen
Standard Competitive       applications, review and score them, and make awards. Figure 2 provides
Award Process, but         an overview of Labor’s TAACCCT grant award process. In all, 258
                           institutions applied for the grant. 18 Once Labor received the applications,
Making Awards to Each
                           it screened and excluded from further review any that did not address one
State Created Challenges   or more requirements of the SGA. Labor also screened the grantees to
for Labor, States, and     identify any that had been excluded from consideration from other federal
Grantees                   grants. 19 For funded grant applications we reviewed, we found that Labor
                           screened all of them and did not find any adverse issues.

                           For fiscal year 2011, the first year that grant funds for the program were
                           appropriated, Labor awarded 49 grants, ranging from $2.5 million for
                           individual applicants up to $24.7 million for consortium applicants (see
                           table 2). Two grants qualified for and received supplemental funding in
                           excess of Labor’s $20 million cap for consortium applicants by showing,
                           as provided for in the SGA, evidence-based success of the proposed
                           strategies and practices and/or proposing to develop large online or
                           technology-enabled programs designed to reach significant numbers of
                           individuals over a large geographic area. Overall, about 8 percent of
                           funds went to individual institutions and 92 percent went to consortia.
                           Grantees must spend their respective award amount within a 3-year
                           period of performance. This period began October 1, 2011 and will end
                           September 30, 2014. Appendix I contains a list of round one grantees.




                           18
                             This total represents the number of applicants that were paneled and scored; it does not
                           include those that Labor excluded after conducting an initial review.
                           19
                             During this step, Labor checks a database to identify any entities that have been
                           debarred or suspended from receiving federal grants. As part of this process, Labor also
                           checks internal sources to identify any outstanding debts owed by the grantees and to
                           identify any relevant audits or investigations.




                           Page 11                                        GAO-12-954 TAA Community College Grants
Table 2: Community College and Career Training Grants Awarded in Round One

    Number of
    Grants Awarded Grant Type                                                  Award Amount
    23                     Single and multi-state consortia                    $2.5 to $24.7 million
    9                      Individual institutions                             $2.5 to $5 million
                                                           a
    17                     State-designated institutions                       $2.7 million
Source: GAO analysis of Labor documents.
a
 After Labor determined that applicants from these states did not meet the cutoff score for grant
awards, these grantees were designated by state higher education agencies that oversee community
colleges. These grantees were subsequently determined to be eligible to receive a portion of the
remaining grant funds, resulting in grant awards of about $2.7 million each. This, in turn, satisfied the
requirement for minimum grant awards of 0.5 percent of the total funding available. These grantees
include both individual institutions and consortia.


To comply with TGAAA’s requirement to make awards based on merit,
and in accord with its competitive grant award process, 20 Labor relied on
panels of three experts each—some of whom were recommended by
Education on the basis of particular expertise relevant to these grants
(see fig. 2). 21 Labor provided an orientation to the peer reviewers to help
them evaluate and score applications. The panels then independently
reviewed the applications and assigned each one a score using the
criteria established in the SGA. The scores were then averaged to
produce a final score for each application. 22 Labor then computed a cutoff
score using total available grant funds as a guide—a standard criterion in
grant award decisions, according to Labor officials. Labor established a
cutoff score of 94 out of 100 for round one; all applicants above this score
were considered for an award, according to Labor. In every instance of
multiple applications submitted from a given state, Labor awarded the
grant to the applicant with the highest score. In case of a tie between



20
 19 U.S.C. § 2371(d)(1)(A). Additionally, the Federal Grant and Cooperative Agreement
Act encourages competition where appropriate, in order to identify and fund the best
possible projects to achieve program objectives. 31 U.S.C. § 6301(3).
21
  Education disseminated Labor’s request for expert reviewers within Education and
among research organizations outside the federal government. These experts served on
the panels along with other experts identified and recruited by a Labor contractor for this
purpose.
22
  The experts recorded their scores, as well as narrative observations about the
applications they reviewed, in workbooks provided by Labor. According to Labor, the staff
members who facilitate these panels may seek clarification from an expert whose numeric
scores and narrative observations regarding a particular application appear inconsistent.




Page 12                                                GAO-12-954 TAA Community College Grants
                                       applicants from the same state, Labor awarded the grant to the applicant
                                       that demonstrated greater evidence of employer engagement. As a result
                                       of the scoring process, Labor initially selected 32 grantees, all of whom
                                       received the full funding amount they requested. Labor clearly
                                       documented the grant award results in a selection memo that provided
                                       the agency’s rationale for awarding the grants.

Figure 2: Process for Reviewing and Scoring TAACCCT Grant Applications




                                       Page 13                               GAO-12-954 TAA Community College Grants
The TGAAA’s requirement that every state 23 receive a minimum amount
of funding created challenges for Labor, states, and selected grantees in
17 states where applicants scored below the cutoff for grant awards.
Labor officials told us that they could not recall another discretionary
Labor grant program with such a requirement. In the absence of such a
precedent, they said that they worked with Education and the Office of
Management and Budget to develop a process that would be clear, fair,
and feasible. This process, as stipulated in the SGA, required Labor to
first select qualified applications from as many states as possible (i.e.,
those that scored at or above the cutoff). In the event that (1) no
applications were received from an eligible institution in a given state or
(2) applications that scored below the cutoff could not be improved by
placing conditions on the grant, Labor would contact the state agency
responsible for the state college system to designate a grantee. Labor
applied this process to the 17 states where institutions did not meet the
scoring cutoff and requested state education agencies to designate a
grantee from their state. 24 Labor accepted the states’ choice of an
institution. Of the 17 states, 6 designated the applicant with the highest
score among multiple applicants from their state; 25 10 designated the only
institution that had applied; and 1 designated an institution that had not
applied.

The requirement to provide each state a minimum level of funding
resulted in some anomalies. While some of the state-designated
grantees’ applications scored close to the cutoff—as high as 92 or 93—
the process resulted in grants to two institutions whose applications had
scores in the upper 50s, well below the threshold of 70 that Labor
considers minimally acceptable for any grant applications to be fundable.




23
  For the purposes of this grant, Labor treated the District of Columbia and Puerto Rico as
states.
24
  Two of the 17 grantees in this group did not go through the paneling and scoring
process—in one case, because the institution submitted its application after the
application deadline; in the other, the state-designated institution submitted its application
after the paneling and scoring phase.
25
 In one of these six states, two institutions tied for the highest score, and the state
designated one of them.




Page 14                                          GAO-12-954 TAA Community College Grants
Figure 3 shows the range of scores and median scores for the initially-
selected grantees, the state-designated grantees, and the unsuccessful
applicants.

Figure 3: Range of Scores and Median Scores for TAACCCT Round One
Applications




Note: The scores shown for the state-designated grantees’ applications reflect the scores assigned
by expert panels to their original applications, not the revised implementation plans that these
grantees developed and that Labor approved. According to Labor, these plans were reviewed to
ensure that they met the requirements of the SGA; however, they did not go through the paneling and
scoring process a second time. Also, the scores for the state-designated grantees’ applications reflect
all those that were scored; two did not go through the paneling and scoring process.


Another anomaly was that Labor awarded a grant to an institution that
had never applied. In this case, instead of designating one of the two
institutions that did apply, the state agency designated an institution from
that state that had not applied. A representative of the state agency
explained that the institution was selected on the basis of its
administrative capacity, the state’s desire to focus on a particular industry,
and the institution’s strong relationships with employers.

The state-designated process was also challenging for states and
grantees. Labor initiated the process of soliciting state agencies’
designations on September 23, 2011, just 7 days before the deadline for
awarding grants at the end of the fiscal year, and gave the states until
September 26, 2011, to designate a grantee. This left states little more
than the weekend to identify an institution (see fig. 4). Of the four state
agencies that we interviewed, all said that they found elements of this


Page 15                                              GAO-12-954 TAA Community College Grants
process to be challenging or confusing. For example, officials in one state
said that the institution they wished to designate was unaware of the
urgency of the situation. In addition, state officials said that they did not
receive guidance or criteria from Labor to help them designate a grantee.
Officials from one state said it was difficult to select a grantee, as all the
applications that institutions from that state had previously submitted
appeared promising. Furthermore, although Labor officials said they took
steps to identify the appropriate state agency point of contact in each
state, officials from one state said there was little evidence Labor had
done so.

Figure 4: Timeline of TAACCCT Grant Program for Round One of Grants




a
 According to Labor, the application period in the first round of the TAACCCT grants was longer than
its typical application periods, which are about 45-60 days.




Page 16                                             GAO-12-954 TAA Community College Grants
States and grantees continued to experience challenges even after the
state-designated grants were awarded because Labor required these
grantees to develop implementation plans to meet the requirements of the
SGA and to obtain Labor’s approval of these plans. All of the grantees
required assistance with this task, some of it significant, according to
Labor officials. Labor’s regional grant staff provided technical assistance
to help these grantees complete their implementation plans, assisted by
specialist staff that Labor tapped for this purpose. 26 In particular, in their
original applications, 14 of these grantees had requested amounts that
were larger—in some cases $20 million or more—than the minimum $2.7
million they ultimately received. Selected state officials and grantees told
us that, as a result, grantees had to significantly scale back their original
proposals and essentially develop new ones from scratch, reflecting
different educational strategies or targeted industries and occupations. 27

In addition, Labor officials told us that they assisted the lowest-scoring of
these grantees to ensure that the grantees’ implementation plans met the
minimum requirements of the SGA. For example, Labor made sure
grantees provided more information about their intended target
population. The revised implementation plans were not, however, re-
scored by the review panels.

The additional time it took Labor to assist grantees in revising their
implementation plans resulted in delayed program implementation for
these grantees. Labor approved the last revised implementation plan in
June 2012, 9 months after awarding the grants. During that time, these
grantees could only charge costs related to revising their implementation
plans and attending a technical assistance conference that Labor
sponsored, according to Labor officials. One grantee noted that the delay
allowed little time to develop new curricula and recruit and enroll students
in time for the fall 2012 semester, as planned. Another noted delayed




26
  Staff from Labor’s Center for Performance Excellence, located in its Philadelphia office,
reviewed the implementation plans. According to Labor, the Center was established to
review earmark grants. Since the Center had applicable expertise, and no earmark grants
were pending at the time, Labor officials asked the Center for assistance.
27
  Labor required all of these grantees to meet the requirements of the SGA, including
focusing on one or more of the grant’s four priorities. However, according to a Labor
official, grantees that scaled back their applications had the option of focusing on fewer of
these priorities, or pursuing a single priority.




Page 17                                          GAO-12-954 TAA Community College Grants
                          implementation, citing a need to move forward with purchasing necessary
                          equipment.

                          While the TAACCCT grants are designed to support grantees’ efforts to
                          serve trade-affected workers, one result of the requirement that every
                          state receive a minimum amount of funding is that some grantees
                          received funding even though they were located in states that are less
                          adversely affected by trade than others. Labor’s recent data on the
                          number of TAA workers suggest that the impact of trade varies widely by
                          state (see app. I). However, eight of the initially-selected grantees were
                          located in 10 states heavily impacted by trade. Of these grantees, seven
                          received grants of $18 million or more each. 28 Moreover, in addition to
                          these grants, training programs in some of the 10 states with the largest
                          TAA worker populations will be offered by institutions that are members of
                          consortia led by other grantees. In these 10 states, 6 had institutions that
                          were members of multi-state consortia.


Labor Has Made a Number   Labor has identified lessons learned from the first round of grants to be
of Modifications to Its   applied to future rounds. The SGA for round two of the grants included
Second Grant              some changes that, according to Labor officials, had the potential to
                          reduce the number of grantees to be designated by state agencies. 29
Announcement
                          Specifically, Labor reduced the maximum dollar amount of grant awards
                          from $5 million to $3 million for individual applicants and from $20 million
                          to $15 million for consortium applicants. Another change from round one
                          to round two that Labor made was to specify that it would select qualified
                          individual grantees before selecting consortium grantees in order to issue
                          an individual grant of at least $2.5 million to an eligible institution in every
                          state. 30 According to Labor, these changes were expected to make it


                          28
                           According to a Labor official, all initially-selected grantees in the first round received the
                          amount they had requested.
                          29
                           Notice of Availability of Funds and Solicitation for Grant Applications for Trade
                          Adjustment Assistance Community College and Career Training Grants Program,
                          SGA/DFA PY 11-08, February 27, 2012.
                          30
                            In contrast to the round one SGA, which specified that Labor would first select grantees
                          that represent as many states as possible, without regard to their status as individual or
                          consortium grantees, the round two SGA specified that Labor would first select qualified
                          individual institutions before selecting consortium grantees to ensure that at least one
                          eligible institution from each state would receive an individual grant of approximately $2.5
                          million. Both SGAs specified that, after these steps, Labor would contact the states that
                          needed to designate grantees.




                          Page 18                                           GAO-12-954 TAA Community College Grants
more likely that an eligible institution in every state could be identified
before the availability of funds criterion is applied. In addition, Labor
officials said they have continued to raise awareness about the grant
opportunity in collaboration with Education by, for example, seeking
Education’s assistance in its outreach efforts and appearing with an
Education official at a conference to discuss the program. The process for
selecting state-designated grantees is otherwise identical to the process
used in round one. Moreover, the SGA for round two stipulates similar
timeframes for applicants to develop and submit their proposals.
Additionally, Labor officials anticipate that some state-designated
grantees in round two will require assistance to revise their
implementation plans and indicated that, based on their experience
during the first round, that process could be completed within about 120
days after the second round grants are awarded. According to Labor, 151
grant applications went through the paneling and scoring process in
round two. Individual institutions or consortium leaders in round one could
only apply as members of a consortium in round two. However,
consortium members and any unsuccessful applicants from round one
were eligible to apply for round two grants. For round two, Labor recently
announced grant awards to 54 grantees and identified 25 states that will
need to designate grantees. 31

Labor made certain other changes to the SGA for round two, beyond
those that address the potential need for state-designated grantees. For
example, in the round two SGA, Labor introduced a mandatory priority for
serving TAA workers and outlined additional flexibility that it will use to
consider heavily trade-impacted areas when making final award
decisions. Labor also added specific requirements to the SGA in certain
areas, such as credit transferability and credentials that facilitate trainees’




31
 In its press release of September 19, 2012, Labor announced 54 awards to 27 consortia
and 27 individual institutions, comprising a total of 297 institutions. Regarding state-
designated grantees in round two, Labor noted its plans to contact 25 states that did not
have a winning individual submission and work with them to develop qualifying projects of
$2.5 million each. Of this group, 15 states had only consortia grantees while 10 states did
not have any grantees. Labor must award these grants by September 30, 2012.




Page 19                                        GAO-12-954 TAA Community College Grants
                         progress, 32 and developing relationships with state agencies that
                         administer TAA programs. Labor officials said that these changes
                         provided more clarification and were partly a response to feedback
                         received during the first round of grants.



Labor Is Tracking and
Addressing Issues
Raised by Grantees,
and Grant
Implementation Is in
an Early Stage
Labor Monitors Grantee   As with its other grant programs, Labor monitors TAACCCT grants in
Progress Using Several   accordance with the guidance and criteria contained in its Core
Mechanisms               Monitoring Guide. 33 On a quarterly basis, federal project officers assess
                         each grant’s overall risk—the likelihood of having a problem with grant
                         integrity and performance—as low, moderate, or high based on the
                         following five areas: (1) program design and governance, (2) program and
                         grant management systems, (3) financial management systems, (4)
                         service and product delivery, and (5) performance accountability. These
                         assessments are made on the basis of the project officers’ review of
                         grantees’ quarterly financial and narrative progress reports, direct
                         communication with grantees, and on-site monitoring as resources
                         permit. 34 As Labor has done for other grant programs, it is developing a


                         32
                           The SGA for round two addresses credit transferability by requiring applicants to ensure
                         that other institutions will recognize credits earned for grant-funded courses and
                         credentials to provide for streamlined transfers. In addition, it requires applicants to design
                         their programs so that they build on previously-learned content, allowing trainees to
                         progress within their programs of study or continue to related programs. It also
                         encourages applicants to work with employers to ensure that grant-funded training results
                         in credentials that are widely recognized by employers and other institutions.
                         33
                           For additional information on Labor’s grant monitoring practices, see GAO, Department
                         of Labor: Further Management Improvements Needed to Address Information Technology
                         and Financial Controls, GAO-11-157 (Washington, D.C.: March 16, 2011).
                         34
                           On-site monitoring of TAACCCT grants has not yet occurred. According to Labor
                         officials, on-site monitoring ideally occurs midway through the grant period, but may occur
                         before or after that point.




                         Page 20                                          GAO-12-954 TAA Community College Grants
                             program-specific monitoring tool that will help officers address oversight
                             priorities and obtain information particular to TAACCCT. For example, the
                             tool will prompt project officers to capture information about the
                             equipment procurement process for consortia members. Labor officials
                             envision that the tool will be particularly helpful during site visits to
                             grantee institutions that are planned to begin in fiscal year 2013.

                             Labor also monitors the grants through TAACCCT-specific grantee
                             reporting requirements. Labor requires that grantees report on a quarterly
                             basis on at least four measures for each strategy identified in their plans
                             to help track implementation progress. Grantees have discretion in
                             identifying the specific measures, but at least two must be output-related,
                             such as the number of students who enroll in particular courses. On an
                             annual basis, grantees must report on seven outcome measures for
                             program participants: (1) entered employment rate, (2) employment
                             retention rate, (3) average earnings, (4) attainment of credits toward
                             degrees, (5) attainment of industry-recognized certificates (in less than 1
                             year), (6) attainment of industry-recognized certificates (in more than 1
                             year), and (7) graduation number and rate for degree programs. 35 The
                             first grantee annual reports are due to Labor on November 14, 2012.
                             Round one grantees must also report these measures for a comparison
                             cohort 36 to help grantees monitor and improve program performance.
                             According to Labor, the cohort requirement is part of the grant’s
                             performance reporting requirement and not directly related to Labor’s
                             evaluation of program effectiveness at this time.


Grant Implementation Is in   Our review of grantee progress reports shows that, as of the quarter
an Early Stage               ending December 2011, most grantees had not yet launched programs or
                             enrolled participants. Instead, they reported building capacity to support
                             the priorities and programs identified in their proposals. 37 For example,


                             35
                               The first three of these measures are common across Labor’s employment and training
                             programs.
                             36
                               A comparison cohort consists of participants who are not in TAACCCT-funded programs
                             but share characteristics with participants who are.
                             37
                               Labor defines launched programs as those “developed, delivered, offered, or improved
                             in whole or in part with grant funds for which the development or improvements have been
                             completed so that they are ready for students to enroll.” We reviewed grantees’ progress
                             reports for the quarter ending December 31, 2011, which were the most recently available
                             reports at the time of our review.




                             Page 21                                       GAO-12-954 TAA Community College Grants
                        most grantees reported hiring key personnel for grant implementation and
                        several reported developing curricula and setting up administrative
                        systems, such as recordkeeping databases to help manage their grant.
                        Nevertheless, a few grantees reported enhancing existing programs and
                        enrolling participants in these programs. Labor’s program guidance for
                        grantees confirms the agency’s expectation that grantees will use the first
                        year of funding to build capacity. As a result, the first year of grantee
                        progress reports are likely to reflect minimal, if any, participant data.

                        Grantee spending levels provide another indication of the early stage of
                        TAACCCT grant implementation. In total, TAACCCT grantees spent 5
                        percent of awarded funds as of the quarter ending March 2012. Grantees
                        have a 3-year window, from October 2011 through September 2014, to
                        spend their award. According to Labor officials, the low percent of funds
                        spent during the first 6 months of the program may be expected given the
                        complexities of administrative set-up, particularly for consortia, which
                        received the majority of grants. In addition, while most grantees had
                        access to funds soon after the grants were awarded, the 17 state-
                        designated grantees had to wait several quarters while awaiting Labor’s
                        approval of their plans. This, in turn, delayed spending. Of the 17 state-
                        designated grantees, 11 received funds during the program’s second
                        quarter (January – March 2012), and 6 received funds during the
                        program’s third quarter (April – June 2012).


Labor’s Monitoring      As of the end of the first quarter of fiscal year 2012, Labor assessed the
Indicates that Most     overall risk of most grants as low. Specifically, 27 of the 49 grants were
Grantees Are Low Risk   assessed as low risk, 19 were moderate risk, and 3 were high risk. A
                        comparison between initially-selected grants and state-designated ones
                        generally showed a similar risk level for each type of grant (see fig. 5).
                        For example, slightly more than half of both the initially-selected grants
                        and state-designated grants were assessed as low risk. However, a
                        higher percentage of state-designated grants were assessed as high risk,
                        compared to the initially-selected grants.




                        Page 22                                GAO-12-954 TAA Community College Grants
Figure 5: Labor’s Overall Risk Assessments by How Grantee was Selected, after
First Quarter of Fiscal Year 2012




While Labor assessed most grants as low risk after the first quarter, many
grantees faced implementation challenges. For example, grantees sought
clarification about tracking and reporting requirements for a single
program with multiple planned improvements. In addition, many grantees
expressed confusion about implementing the comparison cohort
requirement. These implementation issues help explain why Labor
identified performance accountability—more than any other area—as
moderate or high risk for more than a third of grants (see fig. 6).




Page 23                                   GAO-12-954 TAA Community College Grants
Figure 6: Labor’s Risk Assessment of Grants by Risk Area, after First Quarter of
Fiscal Year 2012




Labor responded to implementation challenges by providing additional
guidance to grantees. Specifically, Labor assisted grantees via webinars,
printed responses to frequently asked questions, and direct
communication from their assigned project officer. Labor also held a
conference for grantees in February 2012 to help address implementation
issues. One session, for example, focused on TAACCCT-specific funding
restrictions. With regard to the comparison cohort requirement, Labor
provided responses to frequently asked questions but acknowledged that
the requirement was confusing and that many Labor staff lacked the
technical expertise to assist grantees. Consequently, Labor removed this
requirement from the SGA for round two.




Page 24                                    GAO-12-954 TAA Community College Grants
                       Although Labor is in the early stages of designing an evaluation of the
Labor Plans to         TAACCCT grant program, it plans to evaluate the program at both the
Evaluate the Program   national and grantee level. At the national level, Labor plans to conduct
                       the evaluation in phases, beginning with an initial review of the
at the National and    implementation process across all grantees from the first and second
Grantee Level, but     rounds, followed by a more in-depth analysis of the overall impact of the
Anticipates Some       grant program. Labor is in the process of selecting an independent
                       contractor to conduct the national evaluation and anticipates a contractor
Challenges             will likely begin work by fall 2012. Labor’s Chief Evaluation Officer stated
                       that, given the early stage of program implementation, the contractor will
                       likely begin with an implementation analysis to determine how and to
                       what extent grantees have implemented the activities laid out in their
                       proposals, and whether data systems are in place to capture reliable data
                       needed for a subsequent impact study. This initial analysis will be based
                       primarily on data collected through a survey of grantees, site visits to a
                       sample of grant projects, a review of grantees’ quarterly and annual
                       reports, and information from grantees’ third-party evaluations of their
                       individual projects. The result will likely be a preliminary description of the
                       projects funded by the program and identification of any implementation
                       issues to date.

                       Once the initial analysis is completed and additional outcome data are
                       available from grantees, Labor anticipates conducting a more
                       comprehensive evaluation of the program—possibly an experimental
                       design—to determine the extent to which the program is achieving its
                       objectives and other important outcomes. This form of evaluation will
                       assess program effectiveness by focusing on services delivered by the
                       grantees’ programs and the results of those services. 38 However, the
                       timing of the more comprehensive evaluation will depend on whether
                       grantees have had sufficient time to implement their programs. It will also
                       depend on the availability of observable, long-term outcome data, such as
                       employment outcomes and earnings. Labor indicated that it may be
                       several more years before such an impact evaluation is feasible.

                       At the grantee level, while Labor did not require first-round grantees to
                       conduct a formal evaluation of their individual projects, grantees from the
                       second round are required to contract with a third party entity to design



                       38
                         GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: January
                       2012).




                       Page 25                                    GAO-12-954 TAA Community College Grants
              and conduct an external evaluation of the grantee’s program. This
              evaluation will be paid for with grant funds. In the proposal for the third-
              party evaluation, grantees must present a detailed plan for rigorously
              evaluating the participant outcomes or impacts, including a complete
              description of the study methodology and data collection methods.
              Grantees must submit a final report to Labor at the end of the grant period
              of performance, and at least one interim report—whose timing is to be
              determined by the grantee—on findings-to-date. According to Labor, this
              evaluation will have both a participant outcome component and an
              implementation component so that Labor can learn more about how the
              program has operated. Furthermore, depending on the adequacy of data
              and the designs of grantees' third-party evaluations, Labor expects results
              from the grantees’ evaluations will be incorporated into the Labor-led
              national evaluation.

              Labor anticipates several challenges to conducting the national program
              evaluation. In addition to the timing challenge associated with providing
              grantees sufficient time to implement their programs before the national
              evaluation can get underway, another issue involves obtaining the
              outcome data needed to support the overall program evaluation.
              According to Labor, obtaining consistent and comparable data from
              grantees will be challenging and is dependent on the capabilities of
              grantees’ data systems to collect and track long-term employment
              outcomes data for program participants. Having comparable outcome
              data is important because the goal of an impact evaluation is to determine
              if outcomes are attributable to a program, or if they can be explained by
              other factors. However, Labor noted that this is an issue for all workforce
              programs, in general, and is not unique to this grant program. Another
              challenge Labor cited is obtaining funding to conduct an impact
              evaluation, which is typically expensive and resource intensive. According
              to Labor, no funding has been allocated for conducting evaluations of
              round one or round two; however, it plans to request such authority for
              subsequent rounds. Accordingly, Labor’s fiscal year 2013 budget
              requested authority to reserve up to 3 percent of the funds that have been
              appropriated for the TAACCCT program for fiscal years 2013 and 2014
              for the purposes of program evaluation and technical assistance.


              The TAACCCT program represents a significant investment in the
Conclusions   capacity of community colleges and other eligible higher education
              institutions to serve trade-affected workers as well as dislocated and
              unemployed workers seeking to improve their prospects in the current
              economy. The program’s particular emphasis on the development of


              Page 26                                GAO-12-954 TAA Community College Grants
                     evidence-based strategies, coupled with the grantees’ commitment to use
                     data for continuous improvement, may result in a number of effective
                     practices that could serve as models for other employment and training
                     programs. It is important, therefore, that the grants selected reflect the
                     most promising projects. Ensuring that each state received a minimum
                     amount of funding resulted in Labor non-competitively awarding grants to
                     17 institutions, based on states’ designations, whose initial applications
                     were either not scored or scored below the cutoff following the paneling
                     and scoring process. Moreover, Labor initiated the process for states to
                     designate an eligible institution only days before the grants had to be
                     awarded, leaving states and grantees little more than a weekend to
                     complete this process.

                     While Labor has taken steps in an effort to reduce the number of state-
                     designated grants in the second round, its recent announcement of
                     second round grants indicated that the number of state-designated
                     grantees will be higher than it was for the first round. Moreover, these
                     steps do not provide assurance that states will have adequate advance
                     notice to vet institutions—something that states we contacted found
                     challenging during round one. Without building in adequate time to work
                     with states, Labor may impose an unnecessary burden on states and may
                     contribute to delays in program implementation, depending on the extent
                     to which these grantees require technical assistance to modify their
                     proposal. Without providing states guidance or criteria to inform their
                     decisions about whom to designate, Labor lacks assurance that states
                     will select the best qualified institution.


                     To provide greater assurance that TAACCCT grants are awarded to the
Recommendation for   most promising projects in every state, we recommend that the Secretary
Executive Action     of Labor take steps to more effectively manage the process whereby
                     states designate a grantee. This could include building in additional lead
                     time for states to designate a higher education institution or providing
                     states with guidance to help inform their designation of a grantee.


                     We provided a draft of this report to the Departments of Education and
Agency comments      Labor for review and comment. Education provided technical comments,
                     which we incorporated as appropriate. Labor provided written comments,
                     which are reproduced in appendix II. In its comments, Labor agreed with
                     our recommendation and noted that while it is not able to determine
                     whether a designated recipient is necessary in specific states until after
                     the grantees are selected, it will make efforts to provide as much lead


                     Page 27                                GAO-12-954 TAA Community College Grants
time as possible to states to identify a designated recipient in future
rounds.

We are sending copies of this report to the Secretaries of Labor and
Education, as well as to relevant congressional committees. In addition,
this report will also be available at no charge on GAO’s website at
http://www.gao.gov.

If you or your staff have any questions about this report, please contact
me at (202) 512-7215 or sherrilla@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made key contributions to this report
are listed in appendix III.




Andrew Sherrill, Director
Education, Workforce, and
Income Security Issues




Page 28                                 GAO-12-954 TAA Community College Grants
Appendix I: Grants Awarded in Round One
                                              Appendix I: Grants Awarded in Round One and
                                              TAA Information by State



and TAA Information by State

                                                                                                                      TAA
        a                                                                                                       b             c
State       Grantee Name                                                        Grant Amount Grantee Type             Workers
Initially-selected grantees
AK          University of Alaska Anchorage Community and Technical College      $2,500,000       Single-state         0
                                                                                                 consortium
AL          George C. Wallace State Community College - Hanceville              $9,500,000       Single-state         7,009
                                                                                                 consortium
AR          Northwest Arkansas Community College                                $14,794,422      Single-state         2,353
                                                                                                 consortium
CA          West Hills College Lemoore                                          $19,993,050      Single-state         21,109
                                                                                                 consortium
CO          Community College of Denver                                         $17,256,881      Single-state         2,054
                                                                                                 consortium
DE          Delaware Technical and Community College                            $4,994,200       Individual           8
GA          North Georgia Technical College                                     $2,546,186       Individual           4,561
HI          Honolulu Community College                                          $24,653,118      Single-state         43
                                                                                                 consortium
IA          Northeast Iowa Community College                                    $12,695,959      Multi-state          2,937
                                                                                                 consortium
IL          College of Lake County                                              $19,366,381      Single-state         13,356
                                                                                                 consortium
KS          Washburn University of Topeka                                       $19,619,450      Single-state         1,495
                                                                                                 consortium
MA          Quinsigamond Community College                                      $20,000,000      Single-state         6,744
                                                                                                 consortium
MD          Anne Arundel Community College                                      $19,730,281      Multi-state          735
                                                                                                 consortium
MI          Alpena Community College                                            $2,835,000       Individual           35,939
MN          Northland Community and Technical College                           $4,794,337       Individual           4,130
MO          Ozarks Technical Community College                                  $19,982,296      Single-state         5,991
                                                                                                 consortium
NC          Robeson Community College                                           $18,835,604      Single-state         14,766
                                                                                                 consortium
ND          United Tribes Technical College                                     $18,947,635      Multi-state          453
                                                                                                 consortium
NH          Great Bay Community College                                         $19,974,792      Single-state         682
                                                                                                 consortium
NJ          Raritan Valley Community College                                    $4,620,265       Individual           3,539
NY          Kingsborough Community College                                      $19,860,087      Single-state         8,615
                                                                                                 consortium
OH          Cincinnati State Technical and Community College                    $19,613,306      Multi-state          27,712
                                                                                                 consortium
OR          Clackamas Community College                                         $18,679,289      Single-state         10,079
                                                                                                 consortium




                                              Page 29                                        GAO-12-954 TAA Community College Grants
                                              Appendix I: Grants Awarded in Round One and
                                              TAA Information by State




                                                                                                                      TAA
        a                                                                                                       b             c
State       Grantee Name                                                        Grant Amount Grantee Type             Workers
PA          Community College of Philadelphia                                   $20,000,000      Single-state         15,964
                                                                                                 consortium
RI          Community College of Rhode Island                                   $3,405,023       Individual           775
SC          Florence-Darlington Technical College                               $19,984,039      Single-state         5,430
                                                                                                 consortium
TN          Motlow State Community College                                      $3,291,515       Individual           8,403
TX          Collin College                                                      $19,998,974      Multi-state          12,896
                                                                                                 consortium
VA          Tidewater Community College                                         $24,107,474      Single-state         8,250
                                                                                                 consortium
VT          Community College of Vermont                                        $2,500,000       Individual           375
WA          Spokane Community College                                           $20,000,000      Single-state         5,478
                                                                                                 consortium
WV          Mountwest Community and Technical College                           $5,000,000       Individual           1,943
State-designated grantees
CT          Gateway Community College                                           $2,701,202       Single-state         2,395
                                                                                                 consortium
DC          Community College of the District of Columbia                       $2,701,202       Single-state         0
                                                                                                 consortium
FL          Florida State College at Jacksonville                               $2,701,202       Single-state         3,463
                                                                                                 consortium
ID          College of Southern Idaho                                           $2,701,202       Single-state         968
                                                                                                 consortium
IN          Ivy Tech Community College of Indiana                               $2,701,202       Single-state         12,283
                                                                                                 consortium
KY          Jefferson Community and Technical College                           $2,701,202       Single-state         6,278
                                                                                                 consortium
LA          Baton Rouge Community College                                       $2,701,202       Individual           1,309
ME          Central Maine Community College                                     $2,701,202       Single-state         1,661
                                                                                                 consortium
MS          Itawamba Community College                                          $2,701,202       Single-state         1,876
                                                                                                 consortium
NE          Metropolitan Community College                                      $2,701,202       Single-state         1,077
                                                                                                 consortium
NM          Santa Fe Community College                                          $2,701,202       Single-state         2,278
                                                                                                 consortium
NV          Truckee Meadows Community College                                   $2,701,202       Single-state         63
                                                                                                 consortium
OK          Oklahoma City Community College                                     $2,701,202       Single-state         841
                                                                                                 consortium
PR          Universidad del Este                                                $2,701,203       Individual           138




                                              Page 30                                        GAO-12-954 TAA Community College Grants
                                            Appendix I: Grants Awarded in Round One and
                                            TAA Information by State




                                                                                                                                 TAA
        a                                                                                                                   b            c
State       Grantee Name                                                                 Grant Amount Grantee Type               Workers
SD          Watertown School District dba Lake Area Technical Institute                  $2,701,202          Single-state        794
                                                                                                             consortium
UT          Salt Lake Community College                                                  $2,701,202          Single-state        2,526
                                                                                                             consortium
WY          Northern Wyoming Community College District                                  $2,701,203          Single-state        46
                                                                                                             consortium
                                            Source: GAO analysis of Labor data.
                                            a
                                             Arizona, Montana, and Wisconsin have at least one institution that is part of a consortium led by
                                            institutions from other states, but they do not have institutions that were awarded a grant as an
                                            individual institution or consortium lead. The numbers of TAA workers in these states were 4,531
                                            (Arizona), 418 (Montana), and 10,292 (Wisconsin).
                                            b
                                                For consortia, the name and state of the lead institution are listed.
                                            c
                                             TAA data are for the number of workers associated with certified TAA petitions in fiscal year 2010 as
                                            reported by Labor as of February 24, 2012.




                                            Page 31                                                    GAO-12-954 TAA Community College Grants
Appendix II: Comments from the Department
             Appendix II: Comments from the Department
             of Labor



of Labor




             Page 32                                     GAO-12-954 TAA Community College Grants
Appendix III: GAO Contacts and Staff
                   Appendix III: GAO Contacts and Staff
                   Acknowledgments



Acknowledgments

                   Andrew Sherrill, 202-512-7215 or sherrilla@gao.gov
GAO Contacts
                   In addition to the contact named above, Meeta Engle, Assistant Director;
Staff              Susan Chin, Analyst-in-Charge; Joel Green, and Chris Morehouse made
Acknowledgements   key contributions to this report. Also contributing to this report were Susan
                   Baker, Divya Bali, Jessica Botsford, Susannah Compton, Jessica Gray,
                   Kathy Leslie, Jean McSween, and Mimi Nguyen.




                   Page 33                                 GAO-12-954 TAA Community College Grants
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(131147)
             Page 34                              GAO-12-954 TAA Community College Grants
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