Detailed Information on the
Workforce Investment Act - Migrant and Seasonal Farmworkers Assessment

Working with Congress to end this program, and require the nation's system of 3,500 One-Stop Career Centers to serve farmworkers instead.

Improving partner outreach to increase the number of grant applications received by the program. More applications will strengthen the program's ability to award grants competitively.

Implementing enhanced data validation software to improve data credibility and validity.

Adopting efficiency measures that are linked to performance outcomes, account for all costs, and facilitate comparisons across Department of Labor training and employment programs.

Require specific plans from grantees for how they will partner with local career centers and other Federal programs to improve services and reduce duplication.

Strengthen accountability by instituting common performance measures that will allow comparison between various job training programs. Measures will track employment, retention, and earnings.

Measure: Entered Employment Rate.

Explanation:Percent of participants employed in the first quarter after exit. This is a federal job training program common measure, which enables the National Farmworker Jobs Program (NFJP) to describe in a similar manner the core purposes and results of the program compared to other education, employment and job training programs. For example, while the target populations for NFJP are migrant and seasonal farmworkers, the ultimate outcomes for this program are the same as for all other employment and training programs. Common measures remove a barrier to service integration among programs by ensuring that programs no longer have different definitions and methodologies for measuring performance. In this case, the performance indicator measures how many participants got a job according to the following formula: Of those who are not employed at the date of participation - The number of participants who are employed in the first quarter after the exit quarter divided by the number of participants who exited during the quarter. This definition for entered employment was adopted in PY 2005, while prior years used a slightly different methodology for calculating the result. Experience shows actual performance results for this measure tend to fluctuate from year to year. Based on results data provided in December 2007, a one percent target increase for PY 2007 would equate to an estimated 49 more people who enter employment in the first quarter after exit in PY 2007 over PY 2006 results, if the number of people exiting in PY 2007 remained the same as PY 2006.

Measure: Employment Retention Rate.

Explanation:Percent of participants employed in the first quarter after program exit still employed in the second and third quarters after exit This is a federal job training program common measure, which enables the National Farmworker Jobs Program (NFJP) to describe in a similar manner the core purposes and results of the program compared to other education, employment and job training programs. For example, while the target populations for NFJP are migrant and seasonal farmworkers, the ultimate outcomes for this program are the same as for all other employment and training programs. Common measures remove a barrier to service integration among programs by ensuring that programs no longer have different definitions and methodologies for measuring performance. In this case, the performance indicator measures how many participants retained their employment once placed in a job, according to the following formula: Of those who are employed in the first quarter after the exit quarter - The number of participants who are employed in both the second and third quarters after the exit quarter divided by the number of participants who exited during the quarter. This definition for employment retention was adopted in PY 2005, and made the measure more challenging by including an additional quarter in which a participant needs to be employed. Experience shows actual performance results for this measure tend to fluctuate from year to year. Based on results data provided in December 2007, a one percent target increase from PY 2006 to PY 2007 would equate to an estimated 70 more people who retained employment in the second and third quarters after exit in PY 2007 over PY 2006 results, if the number of people exiting in PY 2007 remained the same as PY 2006.

Measure: Average Earnings.

Explanation:The average six-month earnings This is a federal job training program common measure, which enables the National Farmworker Jobs Program (NFJP) to describe in a similar manner the core purposes and results of the program compared to other education, employment and job training programs. For example, while the target populations for NFJP are migrant and seasonal farmworkers, the ultimate outcomes for this program are the same as for all other employment and training programs. Common measures remove a barrier to service integration among programs by ensuring that programs no longer have different definitions and methodologies for measuring performance. In this case, the performance indicator measures participants' average six-month earnings once placed in a job (note: the average earnings for a year can be obtained by doubling the performance measure result), according to the following formula: Of those participants who are employed in the first, second, and third quarters after the exit quarter - Total earnings in the second quarter plus total earnings in the third quarter after the exit quarter divided by the number of participants who exited during the quarter. For PY 2007, an individual would earn $15,000 annually, $1,250 monthly, and $313 weekly. The common measure definition for average earnings was adopted in PY 2006, while prior year results were for a different earnings measure tracking earnings change.

Measure: Cost per Participant

Explanation:The program calculates the average cost for each participant by dividing the total annual appropriation for the program by the number of participants.

Is the program purpose clear?

Explanation: The program is intended to help economically-disadvantaged migratory and other seasonal farmworkers, and their families, move out of the chronic seasonal unemployment and underemployment that can trap them in a cycle of poverty and lost educational opportunities. The program strives to achieve its mission by funding competitive grants to organizations to provide participants with training and other employment development. However, the Congress has authorized and directed that the program also provide supportive services such as emergency assistance and housing. In fact, annually, most of the approximately 36,000 participants receive only low-cost supportive services. Despite the importance of these supportive services--which help many participants stabilize their budget while they are unemployed--providing them through this Department of Labor (DOL) program detracts from its primary purpose to help farmworkers find more stable, year-round employment.

Evidence: Workforce Investment Act of 1998 (WIA; Public Law [P.L.] 105-220) Section 167 (www.doleta.gov/usworkforce/asp/act.cfm); and wdsc.doleta.gov/msfw/html/docs/facts.cfm

Does the program address a specific and existing problem, interest, or need?

Explanation: The program addresses a significant problem for a large population of farmworkers: they have limited opportunities to move out of a way of life that, due to its dependence on seasonal agricultural labor, is characterized by migration and economic insecurity. According to the Occupational Outlook Handbook (OOH), in 2000, approximately 900,000 people were employed as farmworkers. However, DOL considers this figure to be low, and estimates that the population is closer to 2,700,000. The National Agricultural Workers Survey (NAWS) found that, in 1997-98: (a) An estimated 56% of all farmworkers migrated; (b) These farmworkers are typically employed in agriculture for less than half a year; and (c) They had a median family income of less than $10,000. Further, the NAWS found, farmworkers are typically foreign-born (81%), have completed 6 years of education, and are not fluent in English (more than 90%). The program, which served more than 36,000 participants in 2002, is intended to help them find more stable employment and increase their earnings.

Evidence: WIA Section 167; "Occupational Outlook Handbook, 2002-03 Edition," DOL/Bureau of Labor Statistics www.bls.gov/oco/pdf/ocos285.pdf; estimate of DOL Office of Assistant Secretary for Policy; "Findings from the National Agricultural Workers (NAWS) Survey 1997-1998: A Demographic and Employment Profile of Unite States Farmworkers," Research Report No. 8, DOL, March 2000 (www.dol.gov/asp/programs/agworker/report_8.pdf); and wdsc.doleta.gov/msfw/html/docs/facts.cfm

Is the program designed so that it is not redundant or duplicative of any Federal, state, local or private effort?

Explanation: Although the program funds grants to help meet this population's needs, the training, employment development, and supportive services that it supports are duplicated by services of certain other programs funded by DOL and WIA partners, including other federal agencies. For training and employment services, other WIA programs--including One-Stop Career Centers, formula grants to states for adult training, and the Department of Education's (ED) Adult Education program--are available to help these workers and their families improve their employment opportunities. Many of these programs can also fund certain supportive services. In addition, other federal programs--for example, the Department of Agriculture's (USDA) Women, Infants, and Children (WIC) program--fund supportive services to eligible farmworker families. Further, there are other farmworker-specific federal programs that address non-employment needs including education, health care, and housing.

Evidence: WIA - P.L. 105-220, Sections 121, 131-134; ED's College Assistance Migrant Program (CAMP); ED's High School Equivalency Program (HEP) [authorized by the Higher Education Act of 1965, as amended Sec. 418 (34 CFR Part 206)], www.ed.gov/pubs/Biennial/126.html; the Department of Health and Human Services' (HHS) Migrant Health Program, authorized by the Public Health Service Act, Sec. 330(g) [42 CFR Part 56], www.bphc.hrsa.gov; HHS' Migrant and Seasonal Head Start program, authorized by the Head Start Act, Sec. 637(12) [45 CFR 1301 et. seq.], www.acf.hhs.gov/programs/hsb/hsweb/search.jsp; USDA's WIC program, authorized by Section 17 of the Child Nutrition Act of 1966, www.fns.usda.gov/wic/; and the Department of Housing and Urban Development's (HUD) Rural Housing and Economic Development program (RHED) authorized by the Departments of Veterans Affairs, Housing and Urban Development and Independent Agencies Appropriations Act of 1999.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: Two major design flaws are: (1) limited competition and (2) an earmark for housing grants. (1) The program provides funds to state service areas based on farmworker populations. DOL chooses one grantee from each area through a competition. However, in the first competition required under WIA, in 1999, many service areas had only one applicant. Additionally, DOL had discretion to continue the grants in 2001 for two years without recompeting. On this basis, DOL awarded all previous grantees a continuation grant, even though many grantees performed well below national standards and their own goals. (2) Although 95% of total program funding is for training and supportive services through a sub-program (the National Farmworker Jobs Program (NFJP)), the Congress annually earmarks the remaining 5-6% for housing grants. These grants are similar to Department of Housing and Urban Development (HUD) grants to serve this population, and the housing grantees need not even coordinate with DOL's NFJP. To address the problems, DOL's 2003 Solicitation for Grant Applications (SGA) requires that housing grant applicants demonstrate how they will target funds for temporary, emergency, and permanent housing for NFJP participants.

Evidence: WIA Final Regulations, August 11, 2000 (www.doleta.gov/usworkforce/asp/act.cfm); Federal Register Notice; Solicitation for Grant Applications (SGA) 03-108, April 14, 2003; www.hud.gov/groups/farmworkers.cfm

Is the program effectively targeted, so program resources reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: In general, it is effectively targeted to reach the intended beneficiaries, but not to address the program's primary purpose of improving workers' employment prospects. WIA defines, and the implementing guidance and regulations interpret, the eligibility requirements for a farmworker to participate in the NFJP. Eligibility is tied to economic disadvantage, employment in seasonal agriculture, inability to return to permanent residence within the same workday, or dependency on such a farmworker. Despite the program's purpose of helping these farmworkers find stable, year-round employment, nearly two-thirds of people who exit the program each year have received only low-cost supportive services. For Program Year (PY) 2001, the figure was 15,671--or 62%--of total exiters. These services, although they are important and inexpensive, do not significantly contribute to the primary purpose of this program.

Evidence: WIA Section 167; 112 STAT 1026 and 1027; Farmworker Bulletin 00-02, effective July 1, 2000 (at http://wdsc.doleta.gov/msfw/html/NFJPbulletins.cfm); WIA Farmworker Adult Program Annual report; National Roll-Up for PY 2001 at http://wdsc.doleta.gov/msfw/html/AnnualRpts.cfm; Federal Register Notice: SGA, April 14,2003

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: It is part of the Job Training Common Measures initiative. Accordingly, it has adopted four long-term goals that, beginning in 2004, will better measure the impacts of the program than current measures and allow comparisons across similar programs. DOL is implementing the common measures and will establish numerical targets in 2004. The Administration's WIA reauthorization proposal identifies the common measures and applies them to all WIA programs. The proposal also ends this program, proposing instead that migrant and seasonal farmworkers would be better served through the nationwide network of more than 1,900 comprehensive and 1,600 affiliate One-Stop Career Centers with whom current program grantees are supposed to partner. As long as this program continues, it will be subject to the common measures. Currently, the program uses measures similar to the common measures.

Evidence: WIA Section 136 (29 U.S.C. 2871), including proposed amendments to same in Administration's WIA reauthorization proposal; Training and Employment Notice (TEN) No. 8-02 announcing implementation of the Job Training Common Measures was issued on March 27, 2003; ETA's 2002 Annual Performance Plan (www.doleta.gov/perform/2002pln.pdf); and "Performance Standards and Measures - National Farmworker Jobs Program," OMB Approval No. 1205-0425 (wdsc.doleta.gov/msfw/PDF/PerfStandards.pdf)

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: DOL is implementing the common measures and will establish ambitious numerical targets in 2004. The Administration's WIA reauthorization proposal identifies the common measures and applies them to all WIA programs. The proposal also ends this program, proposing instead that migrant and seasonal farmworkers would be better served through the nationwide network of more than 1,900 local One-Stop Career Centers with whom current program grantees are supposed to partner. As long as this program continues, it will be subject to the common measures. Currently, the program uses measures and targets similar to the common measures.

Evidence: Training and Employment Notice (TEN) No. 8-02 announcing implementation of the Job Training Common Measures was issued on March 27, 2003; ETA's 2002 Annual Performance Plan (www.doleta.gov/perform/2002pln.pdf); and "Performance Standards and Measures - National Farmworker Jobs Program," OMB Approval No. 1205-0425 (wdsc.doleta.gov/msfw/PDF/PerfStandards.pdf)

Does the program have a limited number of specific annual performance measures that demonstrate progress toward achieving the program's long-term measures?

Explanation: It is part of the Job Training Common Measures initiative. Accordingly, it has adopted four annual goals that, beginning in 2004, will better measure the impacts of the program than current measures and allow comparisons across similar programs. DOL is implementing the common measures and will establish numerical targets in 2004. The Administration's WIA reauthorization proposal identifies the common measures and applies them to all WIA programs. The proposal also ends this program, proposing instead that migrant and seasonal farmworkers would be better served through the nationwide network of more than 1,900 comprehensive and 1,600 affiliate One-Stop Career Centers with whom current program grantees are supposed to partner. As long as this program continues, it will be subject to the common measures. Currently, the program uses measures similar to the common measures.

Evidence: WIA Section 136 (29 U.S.C. 2871), including proposed amendments to same in Administration's WIA reauthorization proposal; Training and Employment Notice (TEN) No. 8-02 announcing implementation of the Job Training Common Measures was issued on March 27, 2003; ETA's 2002 Annual Performance Plan (www.doleta.gov/perform/2002pln.pdf); and "Performance Standards and Measures - National Farmworker Jobs Program," OMB Approval No. 1205-0425 (wdsc.doleta.gov/msfw/PDF/PerfStandards.pdf)

Does the program have baselines and ambitious targets and timeframes for its annual measures?

Explanation: DOL is implementing the common measures and will establish ambitious numerical targets in 2004. The Administration's WIA reauthorization proposal identifies the common measures and applies them to all WIA programs. The proposal also ends this program, proposing instead that migrant and seasonal farmworkers would be better served through the nationwide network of more than 1,900 local One-Stop Career Centers with whom current program grantees are supposed to partner. As long as this program continues, it will be subject to the common measures. Currently, the program uses measures and targets similar to the common measures that were adopted using a 2001 baseline.

Evidence: Training and Employment Notice (TEN) No. 8-02 announcing implementation of the Job Training Common Measures was issued on March 27, 2003; ETA's 2002 Annual Performance Plan (www.doleta.gov/perform/2002pln.pdf); and "Performance Standards and Measures - National Farmworker Jobs Program," OMB Approval No. 1205-0425 (wdsc.doleta.gov/msfw/PDF/PerfStandards.pdf)

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, etc.) commit to and work toward the annual and/or long-term goals of the program?

Explanation: When the program was implemented under WIA beginning in 1999 (as a transition from the predecessor Job Training Partnership Act (JTPA) program), grantees were required to address performance in their applications in some manner. In addition, DOL established and published national performance measures and standards. However, the two are not directly linked, and not all grantees must meet the national standards. In 2001, DOL's decision whether to continue grants for another two years was supposed to be based on whether grantees' performance was "satisfactory." Despite these requirements, there is no close connection between individual grantees' commitments, performance, and their continuing as a grantee. So, performance accountability is weak. Program reports as recent as 2001 indicate that there are continuing grantees with performance significantly below the program's goals for national performance.

Evidence: Federal Register Notice: Solicitations for Grant Applications, May 19, 1999, and April 14, 2003; Farmworker Bulletin 01-04 on preparing NFJP Biennial Plans for Program Years 2001 and 2002 (http://wdsc.doleta.gov/msfw/html/NFJPbulletins.cfm); and NFJP Performance Results for Program Year 2001 (http://wdsc.doleta.gov/msfw/PDF/PerfResults01.pdf)

Are independent and quality evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: No independent evaluation of this WIA program has occurred. The predecessor program under JTPA was evaluated for two years in the early 1990s, and the results were published in 1994. Current-program improvements have come about through DOL's administration of the program, including the performance goals.

Evidence: "Evaluation of the JTPA Title IV Migrant and Seasonal Farmworker Program" Research and Evaluation Report Series, Social Policy Research Associates and Berkeley Planning and Associates, 1994 (at http://wdr.doleta.gov/opr/fulltext/document.asp?docn=6136)

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: The Administration proposes to end this program. Instead, eligible farmworkers would receive training and employment services through the nationwide network of more than 1,900 comprehensive and 1,600 affiliate One-Stop Career Centers. They also would continue to receive supportive services through several other agencies, including ED, HUD, and HHS.

Evidence: The President's 2003, 2004, and 2005 Budgets; and the Administration's WIA reauthorization proposal

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: As part of the Job Training Common Measures initiative, the program has adopted four long-term and annual goals and will establish numerical values for those goals in 2004. In addition, the SGA for new grants that will begin in PY 2003 (initiated on July 1, 2003) requires that applicants promote increased participation and co-enrollment of farmworkers in all the services available through the nationwide network of more than 1,900 comprehensive and 1,600 affiliate One-Stop Career Centers. Applicants also must collaborate and coordinate with these centers to deliver services. These changes address a problem with the grants to date: grantees were supposed to coordinate their services with One-Stop centers, but integration was spotty.

Evidence: Federal Register Notice; SGA 03-108, April 14, 2003; TEN No. 8-02 announcing implementation of the new Job Training Common Measures, March 27, 2003

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: Data are collected from NFJP grantees on a quarterly basis, and the resulting analysis is used to measure performance against annual goals set for the program at the national level. The Federal Project Officers provide (either directly or through a third party arrangement) technical assistance to grantees whose performance falls short of the established goals for the particular program.

Evidence: GAO Report 01-251: "Labor Challenges; National Farmworker Jobs Program". The ETA Report 9094 [WIA Program Planning Summary Title I-D, Section 167 - National Farmworker Jobs Program (NFJP)] and ETA Report 9095 [WIA Program Status Summary Title I-D, Section 167 - National Farmworker Jobs Program (NFJP)], OMB Approval No. 1205-0425, collect quarterly information from grantees. These forms are accessible at http://wdsc.doleta.gov/msfw/html/forms.cfm. ETA prepares Quarterly Program Reviews, which are used in program management. The most recent Quarterly Reviews were compiled for the quarters ending December 31, 2002; March 31, 2003; and June 30, 2003. The WIA Farmworker Adult Program Annual Report and National Roll-Up for PY 2001 also provide performance information.

Are Federal managers and program partners (grantees, subgrantees, contractors, cost-sharing partners, etc.) held accountable for cost, schedule and performance results?

Explanation: As discussed in the explanation for the answer to question #2.5, grantees are not required to meet specific performance targets that support the national goals, though they are generally to be accountable financially and administratively as a condition of the grant award. Performance results as recent as 2001 confirm that some grantees demonstrate persistent problems in achieving and reporting their performance toward the national goals. Despite this consistently poor performance of some grantees, there were no sanctions, and all current grantees received a two-year continuation grant in 2001. Performance ratings for federal program managers, on the other hand, are tied to ETA and program performance goals and to grants management responsibilities. All ETA managers and staff are held accountable through incorporation of relevant elements and performance standards in the appraisal process. Also, ETA's Office of Financial and Administrative Management routinely provides to managers and regions reports and analysis of cost and performance results.

Evidence: "Performance Standards and Measures - National Farmworker Jobs Program," OMB Approval No. 1205-0425 (http://wdsc.doleta.gov/msfw/PDF/PerfStandards.pdf); NFJP Performance Results for Program Year 2001 (http://wdsc.doleta.gov/msfw/PDF/PerfResults01.pdf); Draft Performance Standards: Administrator, Office of National Programs; and 20 CFR 669.230, which provides for terminating a grantee's designation to protect federal funds or when there are substantial and persistent violations of the Act or regulations, but does not provide for sanctions for significant failure to meet performance goals. Revised DOL performance management plans for senior executives (Form DL 1-2059, Rev. 10/2001) and for supervisors and managers (Form DL 1-382, Rev. 10/2001)

Are all funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: Federal funds are fully obligated annually to the NFJP grantees and the farmworker housing assistance grantees. All grants are subject to annual compliance audits under the Single Audit Act and periodic compliance audits by the Office of the Inspector General (OIG). ETA works with grantees to correct any problems identified by audits. No systemic problems have been identified through audits.

Evidence: The FY 2002 Financial Performance Report from the OIG did not identify any reportable conditions for the NFJP (www.dol.gov/_sec/media/reports/). OIG audits of this program are accessible at www.oig.dol.gov/cgi-bin/oa_rpts.cgi?s=farmworker&y=all&a=all and wdsc.doleta.gov/msfw/html/ProgAudits.cfm.

Does the program have procedures (e.g., competitive sourcing/cost comparisons, IT improvements, approporaite incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: As part of the Job Training Common Measures initiative, the program is adopting a common measure of efficiency. However, the program already collects data for the NFJP that are needed to calculate the cost of its services per participant.

Evidence: Annual Financial Status and Program Status Reports (at http://wdsc.doleta.gov/msfw/html/AnnualRpts.cfm), which show overall NFJP 2001 unit cost of about $1,940, unit cost for intensive and training services of about $2,180, and unit cost for related/supportive assistance of about $340; and Federal Register Notice: SGA, April 14, 2003

Does the program collaborate and coordinate effectively with related programs?

Explanation: The NFJP is a required partner in the One-Stop Career Center system in those local areas where it is present. Although some grantees have succeeded in developing a participatory role for the NFJP in their local workforce areas and centers, in many localities and states, there is little integration of services between the local workforce investment board(s) and the state area's NFJP grantee. These failures may be the responsibility not only of NFJP grantees, but also state and/or local workforce systems. Nationally, this program does not coordinate effectively with programs of other federal agencies including ED, HUD, and HHS, that also are available to serve farmworkers and their families. To address this lack of coordination and to increase farmworkers' access to One-Stop Career Centers, the NFJP SGA for PY 2003 requires grantees to propose how they will remove barriers and disincentives to serving farmworkers, and collaborate and coordinate with One-Stop centers to improve service integration for farmworkers.

Evidence: Federal Register Notice: SGA, April 14, 2003.

Does the program use strong financial management practices?

Explanation: The FY 2002 Financial Performance Report from the OIG did not identify any reportable conditions for the NFJP, and ETA and DOL programs are free of material internal control weaknesses. With respect to this program, in particular: prior to making awards, ETA reviews available records of potential grantees to assess the organization's overall responsibility to administer federal funds. In those relatively few instances in which problems are identified--for example, costs that should not have been allowed--ETA works with the grantee to rectify the situation and, as necessary, provide technical assistance. Like the rest of DOL, this program will benefit from the new departmentwide effort to institute managerial cost-accounting to allow managers to integrate financial and performance information and use it on a routine basis.

Evidence: 20 CFR 667.170; The FY 2002 Financial Performance Report from the OIG did not identify and reportable conditions for the NFJP. The report is accessible at www.dol.gov/_sec/media/reports/.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The SGA for new grants that will begin in PY 2003 (initiated on July 1, 2003) requires that applicants promote increased participation and co-enrollment of farmworkers in all the services available through the nationwide network of more than 1,900 comprehensive and 1,600 affiliate One-Stop Career Centers. Applicants also must collaborate and coordinate with these centers to deliver services. These changes address a problem with the grants to date: grantees were supposed to coordinate their services with One-Stop centers, but integration was spotty.

Evidence: Federal Register Notice: SGA, April 14, 2003

Are grants awarded based on a clear competitive process that includes a qualified assessment of merit?

Explanation: Grants are awarded competitively, but the competition is severely limited due to an inadequate applicant pool and little emphasis on performance accountability. First, there is an allotment of funds to 47 state service areas and Puerto Rico based on farmworker populations. Then, DOL chooses one grantee, through competition, from each area. WIA requires that an NFJP competition be conducted every two years, but authorizes DOL to waive this requirement for an additional two years if grantees are performing satisfactorily and upon receipt of an acceptable plan for the succeeding two years. Also, organizations must undergo a financial responsibility test before any award is made. Despite this competitive framework, for the first competition in 1999, many areas had only one applicant. Further, "satisfactory" performance is determined administratively, with no clear definition linked to achievement of performance goals tied to national standards. As a result, in 2001, all previous grantees received a waiver and two-year continuation grant, even though many of them performed well below national standards and goals.

Evidence: WIA Section 167; Federal Register Notice: SGA, April 14, 2003; and Farmworker Bulletin 01-04, which addresses requirements for preparing the NFJP Biennial Plans

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The NFJP program provides services through state service area grantees but is nationally administered. The program's project officers communicate with the 53 grantees using the telephone, e-mail, and letters. This approach, and the relatively small size of the program, allows them to provide oversight and technical assistance on a routine basis. The results of monitoring visits (whether onsite or through a desk review) are documented via reports that are sent to the grantee and become part of the grant files. Fiscal reviews are also being conducted for selected grantees. Additional information is collected through the grantees' quarterly reports.

Evidence: Monitoring visit reports for Mississippi and Idaho; and a fiscal review report for CHDC by Planmatics, Inc. These reports can be obtained by contacting ETA.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: The program collects information on a quarterly basis; results are collected and analyzed by ETA's Performance and Results Office for distribution as a Quarterly Program Review. In addition, the annual performance data are collected and analyzed, and results are posted in the ETA/MSFW website on an annual basis.

Evidence: Annual Reports (at wdsc.doleta.gov/msfw/html/AnnualRpts.cfm); National Rollup for PY 2001 (at wdsc.doleta.gov/msfw/PDF/PerfResults01.pdf); and ETA Quarterly Program Reviews (accessible at www.doleta.gov/usworkforce/performance/).

Has the program demonstrated adequate progress in achieving its long-term outcome performance goals?

Explanation: It has adopted four new long-term goals as part of the Job Training Common Measures initiative. DOL will establish numerical annual and long-term targets in 2004. Partial credit is based on the fact that DOL achieved two of three annual goals for its previous measures in PY 2001, supporting achievement of long-term goals. Consistent with the program's primary purpose, current measures relate only to employment and training services provided through NFJP, which account for more than 80% of NFJP spending. However, these measures affect only 38% of total program exiters. The program does not measure its related assistance services, which account for only 9% of spending, but are the only services that 62% of program exiters receive. There also are no measures for the earmarked housing assistance grants.

Evidence: Annual Reports (at wdsc.doleta.gov/msfw/html/AnnualRpts.cfm); National Rollup for PY 2001 (at wdsc.doleta.gov/msfw/PDF/PerfResults01.pdf); and ETA Quarterly Program Reviews (accessible at www.doleta.gov/usworkforce/performance/).

Does the program (including program partners) achieve its annual performance goals?

Explanation: It has adopted four new annual goals as part of the Job Training Common Measures initiative. DOL will establish numerical annual and long-term targets in 2004. Partial credit is based on the fact that DOL achieved two of three annual goals for its previous measures in PY 2001. However, many grantees' performance fell significantly below the national goals. Consistent with the program's primary purpose, current measures relate only to employment and training services provided through NFJP, which account for more than 80% of NFJP spending. However, these measures affect only 38% of total program exiters. The program does not measure its related assistance services, which account for only 9% of spending, but are the only services that 62% of program exiters receive. There also are no measures for the earmarked housing assistance grants.

Evidence: Annual Reports (at wdsc.doleta.gov/msfw/html/AnnualRpts.cfm); National Rollup for PY 2001 (at wdsc.doleta.gov/msfw/PDF/PerfResults01.pdf); and ETA Quarterly Program Reviews (accessible at www.doleta.gov/usworkforce/performance/).

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program performance goals each year?

Explanation: The program's spending is consistent with the authorization and appropriations. However, there is little or no interaction with other WIA programs and federal agencies that could better provide supportive services, thereby freeing up NFJP funds for an even greater focus on providing training and employment development services. As part of the Job Training Common Measures initiative, the program is adopting a common measure of efficiency intended to strengthen its effectiveness. Despite this measure, the program will still be required to spend 5-6% on housing assistance grants due to the congressional earmark, which detracts from the primary purpose of the program.

Evidence: Annual Reports (at wdsc.doleta.gov/msfw/html/AnnualRpts.cfm); National Rollup for PY 2001 (at wdsc.doleta.gov/msfw/PDF/PerfResults01.pdf); and ETA Quarterly Program Reviews (accessible at www.doleta.gov/usworkforce/performance/).

Does the performance of this program compare favorably to other programs, including government, private, etc., that have similar purpose and goals?

Explanation: For training and employment services, this program may be compared to the WIA Adults program. Although that program does not focus on migrant and seasonal farmworkers or face the particular challenges that their employment entails, it does serve disadvantaged people. In PY 2001, the WIA Adults program served an estimated 388,800 participants. For PY 2001, on comparable measures, the WIA Adults program's employment rate was 76%, while the NFJP rate was 74%; but the WIA Adults retention rate was 81%, while the NFJP rate was 64%. However, the average earnings gain over six months was $3,312 for WIA Adults, while the NFJP average gain was $3,750. The WIA Adults unit cost is a few hundred dollars more than the unit cost for this program's intensive and training services ($2,180). For supported or "related assistance" services and housing, it is difficult to compare this program with others because it does not have performance measures in place to do so.

Evidence: For this program, National Rollup for PY 2001 (at wdsc.doleta.gov/msfw/PDF/PerfResults01.pdf); for WIA Adults program, PY 2001 WIA Annual Reports, National Summary (at www.doleta.gov/usworkforce/documents/AnnualReports/annual_report_2001.asp)

Do independent and quality evaluations of this program indicate that the program is effective and achieving results?

Explanation: No independent evaluation of this WIA program has occurred. The predecessor program under JTPA was evaluated for two years in the early 1990s, and the results were published in 1994. That evaluation indicated that the program was substantially meeting its goals at that time and recommended additional capacity building and program integration to more effectively deliver services. However, that evaluation did not comment on the program's impact.

Evidence: "Evaluation of the JTPA Title IV Migrant and Seasonal Farmworker Program" Research and Evaluation Report Series, Social Policy Research Associates and Berkeley Planning and Associates, 1994 (at http://wdr.doleta.gov/opr/fulltext/document.asp?docn=6136)