MEMORANDUM FOR:                 RAYMOND L. BRAMUCCI
                                                           Assistant Secretary for Employment
                                                               and Training
 

                                                                / s /
FROM:                                             JOHN J. GETEK
                                                          Assistant Inspector General
                                                              for Audit
 

SUBJECT:                                       School-to-Work Opportunities Program In Iowa
                                                          Final Audit Report No.: 05-98-006-03-385
 

The attached subject final audit report is submitted for your resolution action.  We
request a response to this report within 60 days.

We would appreciate your office transmitting this report to the Iowa Department
of Education as part of your audit resolution process.

If your staff has any questions, they should contact Preston Firmin, Regional Inspector General in Chicago at (312) 353-2416.
 

Attachment
 

cc:    Ms. Stephanie Powers, Director
         National School-to-Work Opportunities Office

Acronyms/Abbreviations                                                         iii

Executive Summary:

Results of Audit                                                                                  v
Auditor's Conclusion                                                                           vi

Section I -- Results of Audit                                                                  2

Chapter 1 -- Introduction:

Federal School-to-Work Background                                                     3
Iowa's History of Interdepartmental Collaboration                                 3
School-to-Work Background in Iowa                                                      5
School-to-Work Grant History                                                                8
Principal Criteria:

Elements of Sustainability                                                             9
School-to-Work Opportunities Act of  1994                                 9

Objective, Scope, and Methodology                                                      13

Chapter 2 -- Findings and Recommendations:

1.    Student Participation in School-to-Work Activities Is Not
       a Statewide Graduation Requirement                                              14
2.    State Certification Requirements for Teachers and Guidance
       Counselors Lack Mandatory School-to-Work Training                    17
3.    The Development of Iowa's Integrated Information System
       Needs To Be Expedited                                                                    20

Section II -- Sustainability

Chapter 1 -- Legislation / Policies                                                           23

Chapter 2 -- Governance                                                                           31

Chapter 3 -- Performance Indicators                                                        35

Chapter 4 -- Incorporation of Other Programs                                          40

Chapter 5 -- Leveraged Funds                                                                  44

Chapter 6 -- Involvement of Stakeholders                                                49

Chapter 7 -- System Roll-out to Regional and
                   Local Partnerships                                                               52

Chapter 8 -- Incentive/Reward Structure                                                 57

Chapter 9 -- Certification of Teachers and Guidance
                   Counselors                                                                          60

Chapter 10 -- Skill Certificates/Portable Credentials                             62

Chapter 11 -- Public Message/Outreach                                                 66

Appendix A

Employment and Training Administration Response
to Draft Report                                                                                         71

Iowa Department of Education Response to Draft Report                       75

ABI                             Iowa Association of Business and Industry

ACT                           American College Testing

The Act                     School-to-Work Opportunities Act of 1994

AEA                          Area Education Agency

BEDS                        Basic Educational Data Survey

CETA                       Comprehensive Employment and Training Act

CGA                      Consolidated Grant Application

DE                             Iowa Department of Education

DED                          Iowa Department of Economic Development

DJCC                        Denison Job Corps Center

DOL                      U.S. Department of Labor

ESP                          Enterprise Strategic Planning

ETA                       Employment and Training Administration

ICA                           Iowa Code Annotated

ICN                           Iowa Communications Network

IIS                              Iowa's Integrated Information System

ISEA                          Iowa State Education Association

IWD                           Iowa Workforce Development

JTPA                         Job Training Partnership Act

LPC                           Local Partnership Coordinator

NCDG                       National Career Development Guidelines

NSTWO                    National School-to-Work Opportunities Office

OIG                           Office of Inspector General

Perkins Act               Carl D. Perkins Vocational and Applied Technology Education Act

SHIP                          State Human Investment Policy

STW                          School-to-Work

TAC                        Technical Assistance Center

TARGET Alliance    The Alliance to Generate Employment and Training
                                    in Iowa

Tech Prep                  Technical Preparation

The U.S. Department of Labor, Office of Inspector General (OIG) has completed a performance audit of the School-to-Work Opportunities Implementation Grant for the period October 1, 1995 (grant award) through May 29, 1998.

Results of Audit:

Our performance audit disclosed that the Iowa legislature, the Iowa Department of Education (DE), and the Iowa School-to-Work (STW) Administrative Team have initiated numerous actions that, when fully implemented, should ensure the sustainability of the STW initiative in Iowa after the STW Federal funding ceases. Some notable examples include the enactment of State law, the establishment of supportive policies and strategies, and the active interdepartmental participation and leadership of State government (See Chapters 1 through 11 of Section II). However, our audit identified the following potential limitations where enhancements can be made:

1.     Student participation in STW activities is not a statewide graduation
        requirement.

2.     State certification requirements for teachers and guidance counselors
        lack mandatory STW training.

3.     The development of Iowa's Integrated Information System (IIS) needs
        to be expedited.

1.     establishing student attainment in all STW components (i.e. school-based
        learning, work-based learning, and connecting activities) as an Iowa high
        school graduation prerequisite;

2.     incorporating STW-related training into State certification requirements
        to make certain that teachers and guidance counselors are properly trained
        and have acquired the necessary skills; and

3.     implementing Iowa's Integrated Information System (IIS) as soon as
        possible.

DE officials believe that collaborating with DOL-ETA officials on establishing graduation requirements would only aid in promoting the current fear that the Federal and State governments desire to eliminate local control.

Yet both DOL-ETA and DE officials agree with the third recommendation. DOL-ETA officials agree that the timely implementation of a sound data management system is an important component in the evaluation, accountability, and continuous improvement of STW systems. These officials will encourage Iowa to be more specific about Iowa's plans and timetable for the full implementation of the IIS.

The DE officials state that the basic core of the IIS is nearly complete while other IIS elements may take until the Year 2000 to accomplish. Iowa officials believe they are moving as quickly as possible in assuring a thorough and quality-driven IIS product.

The DOL-ETA response is included as Appendix A. The DE response is included as Appendix B.

Auditor's Conclusion

Although we understand Iowa's fears, the purpose of our review was to provide suggestions for strengthening the sustainability of the Iowa STW initiative, not to impose a Federal mandate. In April 1997, officials from the U.S. Department of Education, Office of Inspector General; the U.S. Department of Labor, Office of Inspector General (DOL-OIG); and the National School-to-Work Opportunities Office (NSTWO) met to formulate an audit plan that would result in providing added value to the NSTWO's program management strategy. The ability of the STW initiative to continue after the expiration of the STW grants was a major area of concern expressed by the NSTWO officials. As a result, officials from the U.S. Department of Education, Office of Inspector General; DOL-OIG; and the NSTWO identified critical elements that are considered to be indicative of a sustainable STW system. This report addresses those elements.

Based on our findings and in consideration of Iowa's response, we have partially resolved the second finding and resolved the third finding. However, the first finding remains unresolved.
 

This report has been prepared to address both potential limitations and planned practices impacting the sustainability of Iowa's School-to-Work (STW) initiative. The following tables summarize the presentation of our report and results of our audit. Table 1 provides an overview of the report format. Table 2 lists each element of sustainability and any associated findings addressing potential limitations.
 

Table 1 -- Report Presentation Overview
Report Sections	Chapter(s)	Descriptions
I  (pp. 2-21)	1  (pp. 2-13)	This chapter starts with an overview of the Federal STW initiative and continues with background information on Iowa's history of interdepartmental collaboration, Iowa's STW initiative, and Iowa's STW grants. The chapter concludes with the principal criteria used to conduct this audit as well as the audit objective, scope, and methodology.
	2  (pp. 14-21)	This chapter presents potential limitations and recommendations where enhancements can be made to further sustain the initiative.
II  (pp. 22-70)	1 through 11	The 11 chapters describe the specific results of our review for each element of sustainability.

 
 

This chapter starts with an overview of the Federal School-to-Work (STW) initiative. The chapter continues with background information on Iowa's history of interdepartmental collaboration, Iowa's STW initiative, and Iowa's STW grants. The chapter concludes with the principal criteria used to conduct this audit as well as the audit objective, scope, and methodology.

Chapter 2 presents potential limitations and recommendations where enhancements can be made to further sustain Iowa's STW system.

Section II of this report discloses the specific results of our review for each of the
11 elements of sustainability.

Federal School-to-Work Background

On May 4, 1994, President Clinton signed the School-to-Work Opportunities Act of 1994 (Public Law 103-239). This law provides seed money to States and local partnerships of business, labor, government, education, and community organizations to develop school-to-work systems. It allows States and their partners to bring together efforts at education reform, worker preparation, and economic development to create a system to prepare youth for the high-skill, high-wage careers of today's and tomorrow's global economy.

The Secretaries of Education and Labor funded activities for the States through Development Grants, to begin to create comprehensive statewide School-to-Work Opportunities systems. The activities must lead to the development of a comprehensive plan for the School-to-Work Opportunities system that addresses the common features, includes the basic program components, and leads to the required outcomes described in the purpose of the School-to-Work Opportunities system. State Implementation Grants enable States to implement their plans for statewide School-to-Work Opportunities systems that will offer young Americans access to programs designed to prepare them for a first job in high-skill, high-wage careers, and for further education and training.

Iowa's History of Interdepartmental Collaboration

Iowa has a history of collaboration concerning workforce development programs dating back to the Comprehensive Employment and Training Act (CETA) program in the 1970's. The CETA program brought together representatives from Job Service, community colleges, community-based organizations, and other groups.

In the early 1980's, the agricultural segment of Iowa's economy was impacted by high interest rates and the value of the dollar. Consequently, the Governor made the retraining of dislocated farmers a major priority under the Job Training Partnership Act (JTPA),
 

Iowa government went through a major reorganization in 1986 that created only a third as many State departments and consolidated many State agencies, boards, and commissions. In this process, JTPA and other State-funded training programs were brought together in the same division of the Iowa Department of Economic Development. This administrative merger expanded the policy horizons for staff of traditional job training programs and highlighted the importance of human resource development for the economic development community.

In the late 1980's, the Governor called together the heads of six State departments to form Iowa's Welfare Reform Coordinating Council. This Council was charged with improving services, including work and training programs, for welfare participants. One resulting initiative became the Promise program to train welfare recipients.

Iowa's Rapid Response program was formalized as a result of the enactment of the Federal Economic Dislocation and Worker Adjustment Assistance Act in 1988 (Public Law 100-418, Title VI, Subtitle D). This program brought state and local job training, employment services, economic development, education, human services, and related officials together in response to plant closings and large layoffs with catastrophic economic impact on workers and communities.

As the decade was coming to a close, the Governor became concerned that workers, businesses, educators, and government officials who were outside of the major communications channels for workforce development programs did not have the necessary information to respond to changes taking place in the workforce and workplace. As a result, the Governor created The Alliance to Generate Employment and Training in Iowa (TARGET Alliance) which was composed of representatives from Iowa government, industry, labor, and education. In the course of their work, the TARGET Alliance members reviewed the various workforce development activities that existed in Iowa. They learned about the large number of distinct programs and were concerned about what appeared to be a fragmented approach to dealing with critical human resource needs.

Consequently, staff from six Iowa Departments (Education, Economic Development, Elder Affairs, Employment Services, Human Rights, and Human Services) began to discuss workforce development programs that could be brought together into a more cohesive system. The group arrived at one overall theme and five general ideas for achieving a more integrated system. The theme was that Iowa needed to pay more attention to the "horizontal" systemic connections between programs and organizations to build in support for local efforts to cross organizational boundaries in providing services to individuals. The five ideas were to:

• establish a Workforce Development Council to oversee all programs
• create local interagency workforce development centers;
• work toward an integrated computer information system to support interagency

efforts;
• work jointly toward influencing Federal laws and regulations that inhibit collaboration; and
• appoint a coordinator responsible for moving these efforts forward.

Since 1994, Iowa has embarked upon an effort to design a STW transition system that emphasizes applied learning in both school and work-based settings to help students achieve better academic skills and better prepare them for their careers.

School-to-Work Background in Iowa

Iowa's STW system is an element of the State's larger workforce development system that is being developed through the collaboration of Iowa Workforce Development (IWD) (formerly the Department of Employment Services), the Iowa Department of Economic Development (DED), and the Iowa Department of Education (DE). Iowa officials acknowledge that an effective STW system depends on the collaboration of business and education. The officials recognize the need to integrate workforce development, education, and economic development policies in order to bring about needed change. Iowa officials also agreed to build their STW system upon the capacity of the existing education and workforce development systems, rather than beginning from scratch.

Iowa's STW vision is to prepare all students to enter and succeed in a changing workplace. By building upon Iowa's foundation of educational excellence, all Iowa students who need further education and training will receive it and Iowa will have a more highly trained, flexible, and productive workforce. Iowa officials are developing an integrated infrastructure that supports business and education partnerships, contextual learning, secondary and post-secondary program planning, work-site learning, and career development.

Iowa officials define STW as a new approach to learning for all students that is based on the proven concept that education works best and is most useful for future careers when students apply what they learn to real life, real work situations.

STW is an integral part of Iowa's school improvement strategy. School improvement in Iowa is systemic reform revolving around Iowa Code Sections 280.12 and 280.18 (see Section II, Chapter 1). As defined by the DE, school improvement:

• calls for fundamental restructuring of educational delivery and a significant shift

in the roles of teachers, administrators, guidance counselors, students, parents, and local partners;
 
• is a continuous process as school districts constantly strive to improve opportunities and achievement levels for students; and

 
• is localized by district and by school and will be different from community to community.

1.   As reported in Iowa's Implementation Grant proposal, dated June 1995
 

Iowa's STW plan is built upon substantial collaboration among IWD, DE, and DED. Iowa has established a state-level, regional-level, and local-level governance structure for the STW initiative.

At the state-level, the STW initiative is administered by the State Directors of IWD, DE, and DED. In addition, a state-level interdepartmental School-to-Work Administrative Team, comprised of officials from IWD, DE, DED, and the Iowa Association of Business and Industry (ABI) (i.e., state-level business partner), is charged with ensuring that:

• STW activities are consistent with the goals and objectives of the three key State departments, and

 
• departments' initiatives and the STW initiatives are resources to each other in the achievement of common goals.

The 15 regional-level STW partnerships [that coincide with Area Education Agency (AEA) boundaries, Iowa's Job Training Partnership Act Service Delivery Areas, and community college districts] provide leadership and technical assistance to local areas that are in the preliminary stages of forming local STW partnerships. AEAs are responsible for delivering education support services to Iowa's K-12 (kindergarten through 12^th grade) school districts. Specifically, AEAs provide school improvement leadership and services to school districts and individual schools in order to enable every student to perform at higher education levels.

Finally, local-level STW partnerships with school districts serving as fiscal agents will implement the STW initiative in concert with school improvement efforts. State mandates for school improvement require that each school district have an advisory committee (comprised of students, teachers, parents, administrators, and community representatives) that makes recommendations to the local school board of education. Four Local Partnership Coordinators assigned to the Iowa STW Office provide leadership and technical assistance to funded local STW partnerships within specified geographical areas.
 

The U.S. Department of Labor (DOL), Employment and Training Administration (ETA)
awarded a $230,000 State STW Development Grant to the DE on March 10, 1994, with a period of performance through December 9, 1994. Three subsequent modifications to the STW Development Grant provided additional funding of $178,892 for a cumulative total of $408,892 and extended the grant's period of performance through February 29, 1996.

The DOL-ETA also awarded a $3.75 million State Implementation Grant to the DED effective October 1, 1995, with a one year period of performance. Modification No. 1, effective September 30, 1996, provided over $7.5 million of additional funding and extended the grant's period of performance through September 30, 1997. Effective December 1, 1996, Modification No. 2 provided additional funding of $120,000 to finance Iowa's STW Institute held February 2 through February 4, 1997 (see Section II, Chapter 11 for more information). Effective September 30, 1997, Modification No. 3:

• provided additional funding of $5.625 million for a cumulative total of $17 million;

 
• extended the grant's period of performance through September 30, 1998; and

 
• changed the State's fiscal agent from DED to DE.

In total, Iowa is projected to receive over $23 million to develop and implement a statewide STW system.

Principal Criteria

Public Law 103-239, School-to-Work Opportunities Act of 1994 (the Act,) contains a sunset provision that mandates the cessation of Federal funding on October 1, 2001. The Act provides seed money to develop and implement school-to-work systems. One of the provisions requires Federal funds under this Act to be used as venture capital, to underwrite the initial costs of planning and establishing statewide STW systems that will be maintained with other Federal, state, and local resources.

Therefore, the Federal seed money must be devoted towards the establishment of an infrastructure that will maintain the STW system when Federal STW funding ceases.
 

In April 1997, officials from the U.S. Department of Education, Office of Inspector General; the U.S. Department of Labor, Office of Inspector General (DOL-OIG); and the NSTWO met to formulate an audit plan that would result in providing added value to the NSTWO's program management strategy. The ability of the STW initiative to continue after the expiration of the STW grants was a major area of concern expressed by the NSTWO officials. As a result, officials from the U.S. Department of Education, Office of Inspector General; DOL-OIG; and the NSTWO agreed to the following 11 elements that are considered to be indicative of a sustainable STW system:

(1) Legislation / Policies
(2) Governance
(3) Performance Indicators
(4) Incorporation of Other Programs
(5) Leveraged Funds
(6) Involvement of Stakeholders
(7) System Roll-out to Regional and Local Partnerships
(8) Incentive / Reward Structure
(9) Certification of Teachers / Guidance Counselors
(10) Skill Certificates / Portable Credentials
(11) Public Message / Outreach.

We believe that the above elements are embraced in Section 213(d) of the Act, which specifies what must be included in a State implementation plan. Those relevant subsections of Section 213(d) are included below. Following each of the numbered subsections to Section 213(d), we have added in bold and enclosed in brackets the related system elements that we believe are embraced by the subsection.

A State plan shall:

(2) describe the manner in which the State will stimulate and support local School-to-Work Opportunities programs and the manner in which the statewide School-to-Work Opportunities system will be expanded over time to cover all geographic areas in the State, including urban and rural areas; [involvement of stakeholders; system roll-out to regional and local partnerships; incentive/reward structure; and public message/outreach]

(3) describe the procedure by which individuals and entities described in subsection (b)(4) (such as Governor, State educational agency, State economic development officials, State employment officials, State job training officials,

State post-secondary education officials, State vocational education officials, State vocational rehabilitation officials, State individual assigned under the
Carl D. Perkins Act, other officials such as the human resource investment council, any private sector representatives that collaborated in the application development) will collaborate in the implementation of the School-to-Work Opportunities system; [legislation/policies; governance; and involvement of stakeholders (state-level)]

(4) demonstrate the support of individuals and entities described in subsection (b) (4), subparagraphs (A) through (J) (such as Governor, State educational agency, State economic development officials, State employment officials, State job training officials, State post-secondary education officials, State vocational education officials, State vocational rehabilitation officials, State individual assigned under the Carl D. Perkins Act, and other officials such as the human resource investment council) for the plan, except in the case where the Governor is unable to obtain the support of such individuals and entities as provided in subsection (a) (2); [governance and involvement of stakeholders (state-level)]

(5) describe the manner in which the State has obtained and will continue to obtain the active and continued involvement, in the statewide School-to-Work Opportunities system, of employers and other interested parties such as locally elected officials, secondary schools and post-secondary educational institutions (or related agencies), business associations, industrial extension centers, employees, labor organizations or associations of such organizations, teachers, related services personnel, students, parents, community-based organizations, rehabilitation agencies and organizations, registered apprenticeship agencies, local vocational educational agencies, vocational student organizations, State or regional cooperative education associations, and human service agencies; [involvement of stakeholders; incentive/reward structure; and public message/outreach]

(6) describe the manner in which the statewide School-to-Work Opportunities system will coordinate with or integrate local school-to-work programs in existence on or after the date of the enactment of this Act, including programs financed from State and private sources, with funds available from such related Federal programs as programs under the Adult Education Act; the Carl D. Perkins Act; the Elementary and Secondary Education Act of 1965; the Higher Education Act of 1965, part F of Title IV of the Social Security Act, Goals 2000: Educate America Act, the National Skills Standard Act of 1994, the Individuals with Disabilities Education Act, the Job Training Partnership Act, the National Apprenticeship Act (1937), the Rehabilitation Act of 1973, and the National and Community Service Act of 1990; [incorporation of other programs and leveraged funds]

(7) describe the strategy of the State for providing training for teachers, employers, mentors, counselors, related services personnel, and others, including specialized training and technical support for the counseling and training of women, minorities, and individuals with disabilities for high-skill, high-wage careers in nontraditional employment, and provide assurances of coordination with similar training and technical support under other provisions of law; [legislation/policies; involvement of stakeholders; and certification of teachers/guidance counselors]

(8) describe how the State will adopt, develop, or assist local partnerships to adopt or develop model curricula and innovative instructional methodologies, to be used in the secondary, and where possible, the elementary grades, that integrate academic and vocational learning and promote career awareness, and that are consistent with academic and skill standards established pursuant to the Goals 2000: Educate America Act and the National Skills Standard Act of 1994; [legislation/policies; system roll-out to regional and local partnerships; and skill certificates/portable credentials]

(9) describe how the State will expand and improve career and academic counseling in the elementary and secondary grades, which may include linkages to career counseling and labor market information services outside of the school system; [legislation/policies; incentive/reward structure; and certification of teachers/guidance counselors]

(10) describe the State strategy for integrating academic and vocational education; [legislation/policies and certification of teachers/guidance counselors]

(11) describe the resources, including private sector resources, the State intends to employ in maintaining the statewide School-to-Work Opportunities system when funds under this Act are no longer available; [leveraged funds]

(12) describe the extent to which the statewide School-to-Work Opportunities system will include programs that will require paid high-quality, work-based learning experiences, and the steps the State will take to generate such paid experiences; [incorporation of other programs; involvement of stakeholders (especially employers and students); and incentive/reward structure]

(13) describe the manner in which the State will ensure effective and meaningful opportunities for all students in the State to participate in School-to-Work Opportunities programs; [legislation/policies (indirect); involvement of stakeholders (especially students); system roll-out to regional and local partnerships; incentive/reward structure; and public message/outreach]

(14) describe the goals of the State and the methods the State will use, such as awareness and outreach, to ensure opportunities for young women to participate in School-to-Work Opportunities programs in a manner that leads to employment in high-performance, high-paying jobs, including nontraditional employment, and goals to ensure an environment free from racial and sexual harassment; [involvement of stakeholders and public message/outreach]

(15) describe how the State will ensure opportunities for low achieving students, students with disabilities, school dropouts, and academically talented students to participate in School-to-Work Opportunities programs; [legislation/policies; involvement of stakeholders; incentive/reward structure; and public message/outreach]

(16) describe the process of the State for assessing the skills and knowledge required in career majors, and the process for awarding skill certificates that is, to the extent feasible, consistent with the skills standards certification systems endorsed under the National Skill Standards Act of 1994;
[skill certificates/portable credentials]

(18) describe the manner in which the State will, to the extent feasible, continue programs funded under title III in the statewide School-to-Work Opportunities system; [system roll-out to regional and local partnerships]

(19) describe how the State will serve students from rural communities with low population densities; [involvement of stakeholders; system roll-out to regional and local partnerships; and public message/outreach]

(20) describe how local School-to-Work Opportunities programs, including those funded under Title III, if any, will be integrated into the statewide School-to-Work Opportunities system; [system roll-out to regional and local partnerships]

(21) describe the performance standards that the State intends to meet in establishing and carrying out the statewide School-to-Work Opportunities system, including how such standards relate to those performance standards established under other related programs; [performance indicators] and

(23) describe the procedures to facilitate the entry of students participating in a School-to-Work Opportunities program into additional training or post-secondary education programs, as well as to facilitate the transfer of the students between education and training programs. [legislation/policies; incorporation of other programs; and incentive/reward structure (for students)]

Objective, Scope, and Methodology

Objective

The objective of the audit was to determine if Iowa has institutionalized the elements that are indicative of a sustainable School-to-Work system.

Scope

We completed a performance audit for the period October 1, 1995 through
May 29, 1998. Fieldwork was conducted in Des Moines, Iowa, from
November 13, 1997 through February 12, 1998.

Methodology

For each of the sustainability elements, we interviewed Iowa's key officials involved in the STW initiative. We also reviewed supporting documentation that was provided by these key officials regarding each sustainability element.

We consider the following three items to be potential limitations to the sustainability of Iowa's School-to-Work (STW) initiative.

1.     Student Participation in School-to-Work Activities Is Not a Statewide Graduation
        Requirement

The State of Iowa does not require students to attain STW-related skills for high school graduation. Consequently, Iowa students may not always be instructed in a STW-based education system.

The Executive Summary of the Iowa STW Implementation Grant's Statement of Work states that Iowa's STW ". . . vision for this system is to prepare all students to enter and succeed in a changing workplace." Iowa officials further state on pages 23 and 24 of the Grant's Statement of Work that Iowa's goal is to prepare all Iowa youth for productive employment and further education in a diverse world. The STW system is designed to serve all students in all schools. The STW system is to provide:

• career development activities for all students;
• a career and education plan at the end of the 7^th grade for all students;
• the establishment of career pathways so that all students can gain contextual learning and workplace readiness skills (as measured by the attainment of Tier I, Tier II and Tier III levels) while in high school; and
• an array of opportunities for work-based learning for all students at both middle school and high school.

 
While Iowa's schools and community colleges are locally controlled, both systems operate under the authority of the Iowa State Board of Education, thus enhancing the State's ability to link secondary and post-secondary education. The Board also works with the Iowa universities, the independent colleges, and the workforce development system. The Board's role is to provide leadership and coordination for Iowa's education system, from early childhood through community colleges. Establishing goals for the education system is a major way it fulfills these roles.

We believe the Iowa State Board of Education should establish student participation in all STW components (school-based learning, work-based learning, and connecting activities) as a high school graduation prerequisite for every student. However, the available options that constitute the STW components in each local school can be determined by the local school district.

Recommendation

We recommend that the Assistant Secretary for Employment and Training collaborate with the Iowa Department of Education (DE) and the Iowa interdepartmental STW Administrative Team to further strengthen the sustainability of Iowa's STW initiative by establishing student attainment in all STW components as an Iowa high school graduation prerequisite.

ETA Response

The finding that STW is not a mandated Iowa graduation requirement is an accurate observation. It supports Iowa's strong tradition of local control which is consistent with Iowa's response that it "does not mandate any graduation requirements for local school districts." For that reason, this finding is not a strategy reflected in the State's plan.

Based upon Iowa's response, the U.S. Department of Education's Office of General Counsel's opinion, the State's plan, and our understanding of the flexible intent of the legislation, we disagree with the relevance of this finding. We continue to maintain this is an area solely within the State's purview.

Grantee (DE) Response

Having the Assistant Secretary for Employment and Training collaborate with the DE and the Iowa STW Administrative Team seems to be in conflict with Iowa's local control structure. Iowa does not mandate any graduation requirements for local school districts. They are established at the local community and district level. If we supported the DOL stepping in to "collaborate" with Iowa on establishing a graduation prerequisite, we would only aid in promoting the current fear that the Federal and State governments desire to eliminate local control. Iowa is a strong local control state, and although we can develop standards (i.e., Tier I & II) and recommend their use at the state-level, we cannot establish mandates.

The Iowa STW Office and the STW Administrative Team support and encourage local school districts and communities to review their existing graduation requirements and determine if they support the goals and outcomes they have identified for their STW systems. We will continue to provide technical assistance in developing measurable outcomes and the relationship to graduation requirements. However, the State will not mandate graduation criteria. That is, by Iowa Code, a local education and community decision.

Auditor's Conclusion

We are not mandating that these changes take place. Instead, we are reporting a potential material weakness to system sustainability in which an enhancement can be made to further strengthen the statewide STW system.

As stated within the finding, the Executive Summary of the Iowa STW Implementation Grant's Statement of Work states that Iowa's STW ". . . vision for this system is to prepare all students to enter and succeed in a changing workplace." In addition, page 11 of the Grant's Statement of Work states "Key to the successful development of Iowa's STW System is the degree to which the essential elements of a comprehensive STW system--work-based learning, school-based learning, and connecting activities--are successfully established in communities across the state in both urban and rural settings." Iowa officials further state on pages 23 and 24 of the Grant's Statement of Work that Iowa's goal is to prepare all Iowa youth for productive employment and further education in a diverse world. The STW system is designed to serve all students in all schools. The STW system is to provide:

• career development activities for all students;
• a career and education plan at the end of the 7^th grade for all students;
• the establishment of career pathways so that all students can gain contextual learning and workplace readiness skills (as measured by the attainment of Tier I, Tier II and Tier III levels) while in high school; and
• an array of opportunities for work-based learning for all students at both middle school and high school.

Notwithstanding the vision statement and the goal set forth in the Grant's Statement of Work that the STW system will be designed to serve all students in all schools, DE officials now state that they have no authority to fulfill this goal. As a result, the exposure to the STW method of education (school-based learning, work-based learning, and connecting activities) for the students of Iowa will be controlled by the decisions of Iowa's 370+ school districts. It should be noted that 150+ school districts have yet to receive any STW funding to develop and/or implement a STW-based education system in their districts. We believe that without strong state level guidance and encouragement, the probability that the students in these school districts will be exposed to the STW method of education (school-based learning, work-based learning, and connecting activities) is substantially reduced.

Consequently, we still believe the Iowa State Board of Education should exhaust all available avenues to ensure that all students participate in all STW components (school-based learning, work-based learning, and connecting activities). Although other options may accomplish this objective, we believe that the

establishment of student participation in all STW components as a high school graduation prerequisite for every student is the most effective method.

As a result, our overall recommendation remains unchanged and we consider the finding to be unresolved.

Iowa officials believe educators are receiving sufficient STW training through the Area Education Agencies (AEA) as described in Section II, Chapter 9. However, we found no uniform requirements in place to ensure that teachers and guidance counselors receive STW training as part of the State's certification process of teachers and guidance counselors. Therefore, educators may not always elect STW training.

Attachment 5 of the Iowa Implementation Grant's Statement of Work states that Iowa's STW evaluation system will include state standards for educator preparation that will reflect STW-related skills. The need for educator preparation is also documented in the following strategic plans:

• "Enterprise Strategic Planning" (as described in detail in Section II, Chapter 3), discloses that preparation programs have not prepared educators to understand and teach skills needed for the workplace. Iowa officials must increase the knowledge of educational practitioners about workforce skills.

• The DE Strategic Plan, December 1997 revision, includes two strategies that encourage DE to help schools and communities obtain the necessary skills, competencies, and resources to meet the learning needs of their children and adults. One strategy is to improve the teaching and instructional practices at the classroom level so that the achievement of all students continuously improves. The other strategy is to support educator preparation and professional development programs designed to give educators the skills they need to improve teaching and learning.

• The November 1997 Iowa Workforce Development (IWD) Strategic Plan documents that higher education has the responsibility to ensure that its professional education programs remain current in a rapidly changing world. As work-based learning gains greater acceptance, teacher education programs must expand this approach in their curricula.

• The January 1997 Iowa Department of Economic Development (DED) Strategic Plan provides that all levels of education must teach in a manner which will provide students with the competencies to perform on the job, to

 

participate in family and community life, and to be prepared for lifelong learning.

On the national level, the National School-to-Work Opportunities Office's Report to Congress - Implementation of the School-to-Work Opportunities Act (September 1997) mentions that States and local partnerships recognize that staff development is an investment that will lead to long-term changes in teaching and developing a future workforce. The report also mentions that pre-service and in-service training and credentialing of teachers, which are considered critical to increasing teacher understanding and practice of STW methodologies, are not yet a major focus.

However, the DE does not require STW-related training as a prerequisite to certification or renewed certification to teach in Iowa. Instead, Iowa officials are comfortable that Iowa educators are electing to receive sufficient STW training through the AEAs.

The Iowa STW Co-Director stated that STW training in support of initial educator certification is weak. We believe that in order for STW and school improvement efforts to be successful, professional growth opportunities must be provided to all educators to ensure that they enhance their skills to provide for student needs and raise student achievement. Educators entering the teaching profession familiar with and committed to these efforts will contribute immeasurably to the process and success of STW and school improvement. Therefore, we believe it is necessary for educator preparation to be linked to STW and school improvement reform. We also believe incorporating specific STW-related requirements as a prerequisite to certification and renewed certification to teach is an effective way to ensure that all educators are properly trained.

Recommendation

We recommend that the Assistant Secretary for Employment and Training collaborate with the DE and the Iowa interdepartmental STW Administrative Team to further strengthen the sustainability of Iowa's STW initiative by incorporating STW-related training into State certification requirements to make certain that teachers and guidance counselors are properly trained and have acquired the necessary skills, as envisioned in the various Iowa strategic plans and the Iowa Implementation Grant's Statement of Work.

ETA Response

Under the STW Act, States are required to provide evidence of STW training and technical assistance for teachers, mentors, and counselors. However, the Act does not mandate STW training as part of the State's certification requirements.

Again, this finding does not represent a strategy addressed in the State's plan. Additionally, the State does offer a variety of STW professional development activities through its AEAs. For example, over 5,000 Iowa teachers have participated through State-level institutes, conferences, and other career development activities. Accordingly, we believe Iowa is making adequate efforts in this area. Further, our position remains that these are actions that fall exclusively within the State's domain, not the Federal Government's.

Grantee (DE) Response

The STW Administrative Team will submit a recommendation to the State of Iowa Board of Educational Examiners indicating serious consideration be given to adding STW-related training into the State certification criteria. We will provide support for this recommendation based upon the amount of current professional development taking place at the local level through the AEAs and feedback by local districts regarding the lack of readiness of new teachers entering systems engaged in school improvement and STW elements.

The Iowa AEAs are responsible for providing professional development for teachers currently employed. All professional development opportunities are to be developed based upon a needs assessment conducted by each AEA. In addition, educators receive credit for STW activity presentations at all STW- related conferences. Based on our review of regional-level professional development activities, 14 of the 15 regions are currently providing professional development activities for educators throughout the year. This would indicate to the State that, without mandate, local school districts are requesting STW-related training from their AEAs.

However, this is a State-level responsibility and we believe that involvement from the Assistant Secretary for Employment and Training would only raise levels of concern.

Auditor's Conclusion

We consider the STW Administrative Team's planned submission to the State of Iowa Board of Educational Examiners recommending adding STW-related training into the State certification criteria to be sufficient action to resolve our recommendation for new teachers entering the system.

With respect to ETA's statement that this finding does not represent a strategy addressed in the State's plan, Attachment 5 of the Iowa Implementation Grant's Statement of Work states that Iowa's STW evaluation system will include state standards for educator preparation that will reflect STW-related skills.

Furthermore, it should be noted that the 5,000+ teachers cited in ETA's response represent less than 20 percent of Iowa's approximately 30,000 educators.

We believe that educators that are familiar with and committed to STW methodologies will contribute immeasurably to the process and success of STW and school improvement. Therefore, we believe it is necessary for educator preparation to be linked to STW and school improvement reform. We also believe incorporating specific STW-related requirements as a prerequisite to renewed certification to teach is an effective way to ensure that all educators are properly trained.

Again, we are not mandating that these changes take place. Instead, we are reporting a potential material weakness to system sustainability in which an enhancement can be made to further strengthen the statewide STW system.
As a result, our overall recommendation remains unchanged and we consider the portion of the finding recommending incorporation of specific STW-related requirements as a prerequisite to renewed certification to be unresolved.

In May 1993, Iowa passed a law that required DE, DED, and IWD to jointly establish an integrated management information system (IIS) to provide for a statewide standardized process for collecting multi-agency data (including STW-related data). However, management's current best estimate for implementation of the IIS is sometime during the Year 2000. We believe it is critical for the sustainability of Iowa's STW initiative to have an operational management information system in place which provides management with vital information necessary to effectively manage the STW initiative. We further believe that DE, DED, and IWD should apply the resources necessary to expedite completion and implementation of the IIS at the earliest possible date.

Recommendation

We recommend that the Assistant Secretary for Employment and Training collaborate with the DE and the Iowa interdepartmental STW Administrative Team to further strengthen the sustainability of Iowa's STW initiative by implementing the IIS as soon as possible.

ETA Response

ETA officials concur with this finding. The timely implementation of a sound data management system is an important component in the evaluation,

accountability, and continuous improvement of STW systems. ETA officials will encourage Iowa to be more specific about its plans and timetable for the full implementation of the IIS.

Grantee (DE) Response

The DE officials concur with this finding. The DE officials believe that the basic core of the IIS is nearly complete while other IIS elements may take until the Year 2000 to complete. They also believe they are moving as quickly as possible in assuring a thorough and quality-driven IIS product.

Auditor's Conclusion

We consider the initial action taken by officials from ETA and DE to be sufficient to resolve this finding.

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