34 CFR 361.13(c)(2) lays out the functions that must be reserved solely to the staff of the Designated State Unit (DSU) and those functions may not be delegated to any other agency or individual. At a minimum, these “non-delegable” responsibilities relate to decisions affecting the following:
- Eligibility, the nature, and scope of services and the provision of those services;
- The determination that individuals have achieved employment outcomes;
- Policy formulation and implementation;
- The allocation and expenditure of VR funds; and
- The participation of the DSU in the one-stop delivery system in accordance with Title I.
This is important for you to know and understand. Sometimes, the larger DSA takes action or oversteps regarding the allocation and expenditure of funds and takes that out of the DSU's decision-making. By understanding, you can speak up and inform others about the regulatory requirements.
To-Do List
- Read TAC 12-03
- Understand your non-delegable authority.
As a VR administrator, you are responsible for understanding the required WIOA performance indicators and other measures that help you assess the effectiveness and efficiency of the VR services provided. At its best, data should do more than satisfy reporting requirements; it should inform your policies, procedures, program improvement efforts, and decision-making.
Make it a routine practice to review the validity, accuracy, and reliability of your agency’s data, given its significant role in Federal reporting and in shaping the story of performance, priorities, and outcomes. Periodically compare the data with other VR agencies and available national data to understand performance in the broader context.
Regularly analyze and disseminate data to identify trends, errors, and anomalies that may affect WIOA performance outcomes, goals, strategies, funding decisions, and overall accountability. Ask questions that deepen understanding, support continuous improvement, and strengthen decision-making.
The following resources can help inform WIOA performance accountability, reporting, data validation, and data quality:
- RSA Accountability - Provides resources related to WIOA performance accountability, including VR annual reports, performance assessment results, negotiation tools, Statistical Adjustment Models, and technical specifications for performance indicators.
- RSA Sub-Regulatory Guidance – Provides RSA guidance documents, including relevant Technical Assistance Circulars and Dear Colleague Letters related to WIOA performance accountability, data validation, reporting, and RSA-911 data. Particularly useful guidance includes:
- TAC-17-01: Performance Accountability Guidance for WIOA Core Programs
- TAC-19-01: Guidance for Validating Jointly Required Performance Data Submitted under the Workforce Innovation and Opportunity Act (WIOA)
- TAC-17-04: Guidance on the Use of Supplemental Wage Information to Implement the Performance Accountability Requirements under the Workforce Innovation and Opportunity Act
- TAC-20-02: Negotiations and Sanctions Guidance for WIOA Core Programs
- DCL-25-04: Revised Case Service Report (RSA-911) for the State VR Services and State Supported Employment Services Programs
- RSA Case Service Report (RSA-911) Quarterly Data Dashboard - Disseminated quarterly by RSA to VR directors, this dashboard helps agencies review RSA-911 data, identify reporting errors, compare performance, and track progress toward annual outcomes.
Review financial, program, and performance data together to understand whether resources and services are producing the intended outcomes. When the data does not align with agency priorities, use them to identify gaps, strengthen coordination, and guide decision-making. Strong coordination among program, fiscal, and data staff can reduce silos and support more effective management.
To-Do List
- Ask your agency data specialist for the RSA-generated Quarterly Data Dashboards and review them for understanding.
- Ask your agency financial and program data specialists for any internal/ad hoc reports and queries that are generated to analyze performance and financial position, and review them for understanding.
- Speak with your agency data specialists about comparisons between expenditures and performance measures (e.g., where the agency has training expenditures, are there associated measurable skill gains and credentials?).
- Consider performance measures/outcomes in comparison to the goals of the State Plan.
- If you are in a state with both a General and Blind agency, meet with the other VR agency’s director to discuss joint WIOA performance accountability measures. (Conduct discussions about State requirements about match, maintenance of effort, pre-employment transition services reserve requirements, etc.)
- Meet with WIOA partner directors to discuss WIOA performance measures and data collection/sharing activities