Nevada Department of Education – Adult Education and Family Literacy Act staff:

Nancy Olsen – Adult Education Programs Supervisor/WIOA Title II State Director
Arianna Florence – Business Process Analyst II
Kendra Wastun – Administrative Assistant III

The Nevada Department of Education is an equal opportunity employer and does not discriminate on the basis of race, color, sex, age, religion or religious creed, national origin, sexual orientation, ancestry, or disability.

Introduction

On July 22, 2014, President Obama signed into law the Workforce Innovation and Opportunity Act (WIOA. WIOA is designed to help job seekers access employment, education, training, and support services to succeed in the labor market and to match employers with the skilled workers they need to compete in the global economy. WIOA establishes ambitious goals for the integration of workforce service programs. These goals are intended to maximize the value and benefits of services under federally funded workforce development programs.

As a core partner under WIOA, Adult Education - Title II has certain responsibilities above and beyond what was previously required under the Workforce Investment Act of 1998 (WIA). WIOA places a heavy emphasis on transition from adult basic education to postsecondary education, training, or employment. While WIOA continues to emphasize high school completion for youth and adults, WIOA recognizes that completion of high school is not an end in itself but a means to further opportunities and greater economic self-sufficiency. Through the implementation of career pathways, integrated education and training, and workforce preparation activities, WIOA sets the stage for Adult Education’s important role in workforce development.

The Nevada Unified State Plan implements the Adult Education and Family Literacy Act (AEFLA), Title II of the Workforce Innovation and Opportunity Act of 2014. The Plan provides the framework for the State to make funding decisions for programs, activities and services that include adult education literacy, workplace adult education, family literacy, English language acquisition, integrated English literacy and civics education, workforce preparation, and integrated education and training.

This handbook provides a guide for Adult Education administrators in Nevada. Detailed policies and procedures can be found in all sections of the Nevada Adult Education Administrator’s Handbook. Any program deviations from policies outlined in this handbook must be authorized, per occurrence, in writing by the Nevada Department of Education (NDE) and documentation of the exception approval must be retained by the local provider.

Vision

Nevada Adult Education will be the catalyst to empower and prepare Nevadans to achieve their life goals and aspirations.

Mission

Nevada Adult Education creates innovative and responsive educational opportunities for diverse adult students.

Purpose of Adult Education in Nevada

The purpose of Adult Education in Nevada is to increase the reading, writing, speaking, comprehension, mathematics, and problem-solving skills of adult students so they can achieve their life, work, and educational goals.

Instructional Program Goals

1. To ensure that adult students meet their learning goals and achieve core measures through adult education programs that are effective and of high quality.
2. To encourage providers to integrate technology into instruction and to use technology effectively in reporting program outcomes.
3. To ensure cooperative/collaborative efforts between providers and community resource agencies.
4. To promote workforce preparation and occupational training.
5. To promote family literacy.

Section 1:  Program Administration

1.1 Eligible Provider

The term eligible provider means an organization that has demonstrated effectiveness in providing adult education and literacy activities. Organizations may include:

• a local educational agency
• a community-based organization or faith-based organization
• a volunteer literacy organization
• an institution of higher education
• a public or private nonprofit agency
• a library
• a public housing authority
• a nonprofit institution
• a consortium or coalition of the agencies, organizations, institutions, libraries, or authorities listed in the previous bullets
• a partnership between an employer and any entity listed in the previous bullets

1.2 Eligible Student

A student who is eligible to receive Title II services is one:

• Who has attained 16 years of age;
• Who is not enrolled or required to be enrolled in secondary school under State law
• Who—
  1. Is basic skills deficient;
  2. Does not have a secondary school diploma or its recognized equivalent, and has not achieved an equivalent level of education; or
  3. Is an English language student (section 203(4) of WIOA).

To be served through AEFLA funds students must be at least 16 years of age and not enrolled or required to be enrolled in a secondary school. All persons under the age of 18 must provide documentation showing they have been excused from compulsory school attendance before they can be enrolled. (Nevada Revised Statutes, Chapter 392, Pupils) Programs must retain copies of documentation in the student’s files. Individuals with an F-1 Visa (student visa) status are ineligible for services and shall “not be accorded a course of study in a publicly funded adult education program.” [Source: Foreign Students in Public Schools (state.gov)]

1.3 Program Activities

• Adult Basic Education (ABE): instruction designed for an adult whose Educational Functioning Level (EFL) is equivalent to, or below, an eighth-grade literacy level as described in the National Reporting System EFL guidelines.
• Adult Secondary Education (ASE): instruction designed for an adult whose EFL is equivalent to, or above a ninth-grade literacy level as described in the NRS EFL Guidelines.
• Career Pathways: According to WIOA, the term ‘‘career pathway’’ means a combination of rigorous and high-quality education, training, and other services that—
  1. aligns with the skill needs of industries in the economy of the State or regional economy involved;
  2. prepares an individual to be successful in any of a full range of secondary or postsecondary education options, including apprenticeships registered under the Act of August 16, 1937 (commonly known as the ‘‘National Apprenticeship Act’’; 50 Stat. 664, chapter 663; 29 U.S.C. 50 et seq.) (referred to individually in this Act as an ‘‘apprenticeship’’, except in section 171);
  3. includes counseling to support an individual in achieving the individual’s education and career goals;
  4. includes, as appropriate, education offered concurrently with and in the same context as workforce preparation activities and training for a specific occupation or occupational cluster;
  5. organizes education, training, and other services to meet the particular needs of an individual in a manner that accelerates the educational and career advancement of the individual to the extent practicable;
  6. enables an individual to attain a secondary school diploma or its recognized equivalent, and at least one recognized postsecondary credential; and
  7. helps an individual enter or advance within a specific occupation or occupational cluster (WIOA section 3).
• Career pathways have multiple entry and exit points that allow individuals to achieve education and employment goals over time. Career Pathways may include apprenticeships, on the job training, industry recognized credentials, non–credit training and certificates, credit certificates and degrees. Career pathways used in Integrated Education and Training must at least include the components listed in the WIOA definition.
• Corrections Education: educational programs, such as ABE, ASE, ESL, and peer tutoring, for criminal offenders in correctional institutions and other institutionalized individuals.
• Corrections programs must use Title II funds in accordance with section 225 of WIOA for educational programs for criminal offenders in correctional institutions and other institutionalized individuals, including academic programs for ABE and ASE, ESL, Peer Tutoring, IET, and/or Career Pathways. Corrections programs must give priority to individuals who are likely to leave a correctional institution within five years of participation in the program.
• English as a Second Language (ESL): instruction designed to help English language learners achieve competence in reading, writing, speaking, and comprehension of the English language.
• Family Literacy: activities that are of sufficient intensity and quality to make sustainable improvements in the economic prospects for a family, that better enable parents or family members to support their children’s learning needs, and that integrate all of the following activities—
  1. Parent or family adult education and literacy activities that lead to readiness for postsecondary education or training, career advancement, and economic self-sufficiency;
  2. Interactive literacy activities between parents or family members and their children;
  3. Training for parents or family members regarding how to be the primary teacher for their children and full partners in the education of their children; and
  4. An age-appropriate education to prepare children for success in school and life experiences (section 231(d) of WIOA; 34 CFR 463.30).
• Family Literacy is an optional activity. Programs must not use funds for the purpose of supporting or providing programs, services, or activities for individuals who are not eligible individuals as defined in the Act, except that such agency may use such funds for such purpose if such programs, services, or activities are related to family literacy activities. Prior to providing family literacy activities for individuals who are not eligible individuals, an eligible provider must attempt to coordinate with programs and services that do not receive funding under this title. (34 CFR 463.20 (c))
• Integrated Education and Training (IET): must include three components—
  1. Adult literacy activities as described in 34 CFR 463.30.
  2. Workforce preparation activities as described in 34 CFR 463.34.
  3. Workforce training for a specific occupation or occupational cluster which can be any one of the training services defined in section 134(c)(3)(D) of the Act.
• In order to meet the requirements that the adult literacy activities, workforce preparation activities, and workforce training be integrated, services must be provided concurrently and contextually such that—
  1. Within the overall scope of a particular integrated education and training program, the adult literacy activities, workforce preparation activities, and workforce training:
     1. Are each of sufficient intensity and quality, and based on the most rigorous research available, particularly with respect to improving reading, writing, mathematics, and English proficiency of eligible individuals;
     2. Occur simultaneously; and
     3. Use occupationally relevant instructional materials.
  2. The integrated education and training program has a single set of learning objectives that identifies specific adult literacy content, workforce preparation activities, and workforce training competencies, and the program activities are organized to function cooperatively. (34 CFR 463.37)
• Programs meet the requirement that the integrated education and training program is for the purpose of educational and career advancement if the adult literacy component of the program is aligned with the state’s content standards and the integrated education and training program is part of a career pathway. (34 CFR 463.38)
• Integrated English Literacy and Civics Education (IELCE): services provided to English language students who are adults, including professionals with degrees and credentials in their native countries that enable such adults to achieve competency in the English language and acquire the basic and more advanced skills needed to function effectively as parents, workers, and citizens in the United States. Such services must include instruction in literacy and English language acquisition and instruction on the rights and responsibilities of citizenship and civic participation, in combination with integrated education and training activities (see section 243(a) of WIOA).
• Programs that receive funding under section 243 must be designed to prepare adults who are ELLs for, and place them in, unsubsidized employment in in-demand industries and occupations that lead to economic self-sufficiency and integrate with the local workforce development system and its functions to carry out the activities of the program.
• IELCE programs must include:
  1. Instruction in literacy and English language acquisition and instruction on the rights and responsibilities of citizenship and civic participation; and
  2. IET activities must include ABE/ASE and/or ESL, Workforce Preparation, and Workforce training for a specific occupation or occupational cluster (34 CFR 463.73).
• Workforce Preparation: include activities, programs, or services designed to help an individual acquire a combination of basic academic skills, critical thinking skills, digital literacy skills, and self-management skills, including competencies in—
  1. Utilizing resources;
  2. Using information;
  3. Working with others;
  4. Understanding systems;
  5. Skills necessary for successful transition into and completion of postsecondary education or training, or employment; and
  6. Other employability skills that increase an individual’s preparation for the workforce.
• Programs must offer Workforce Preparation concurrently with another activity such as ABE, ASE, ESL, IET, or IELCE and be consistent with the organizational requirements for those activities.
• Workplace Adult Education: activities include ABE, ASE, or ESL content which addresses the improvement of the productivity of the workforce. Workplace Adult Education activities are offered by programs in collaboration with an employer or employee organization at a workplace or an offsite location.

Section 2: Funding and Fiscal Management

Title II programs are authorized by the Workforce Innovation and Opportunity Act (Public Law 113-128 (29 U.S.C. Sec. 3101, et. seq.)) (WIOA) of 2014, Adult Education and Family Literacy Act (Title II). Regulations and guidelines governing programs are codified in the Code of Federal Regulations (CFR), Title 34 CFR Parts 461, 462, 463 et al. and Title 2 CFR 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).The purpose of this section is to facilitate the state, regional and local coordination and fiscal management of federal grants administered under the authority of the AEFLA. This section is designed to consolidate federal and state procedures required for budget management.

2.1 Federal Funding

NDE distributes federal funds provided by the Adult Education and Family Literacy Act (AEFLA) in accordance with the provisions set forth in the Act. The Basic State Grant is distributed to individual programs as subgrants; funds are allocated as follows:

• State Administration of the Program (not more than 5.0%)
• State Leadership Projects (not more than 12.5%)
• Programs of Instruction (remaining funds, at least 82.5%)

Local Providers

Local providers are awarded AEFLA federal and state funds through a competitive grant process with the State using the following required considerations (WIOA Title II Section 231 (e)) as a part of the review of applications:

1. The degree to which the eligible provider would be responsive to— (A) regional needs as identified in the local plan under section 108; and (B) serving individuals in the community who were identified in such plan as most in need of adult education and literacy activities, including individuals— (i) who have low levels of literacy skills; or (ii) who are English language students.
2. The ability of the eligible provider to serve eligible individuals with disabilities, including eligible individuals with learning disabilities.
3. Past effectiveness of the eligible provider in improving the literacy of eligible individuals, to meet State-adjusted levels of performance for the primary indicators of performance described in section 116, especially with respect to eligible individuals who have low levels of literacy.
4. The extent to which the eligible provider demonstrates alignment between proposed activities and services and the strategy and goals of the local plan under section 108, as well as the activities and services of the one-stop partners.
5. Whether the eligible provider’s program— (A) is of sufficient intensity and quality and based on the most rigorous research available so that participants achieve substantial learning gains; and (B) uses instructional practices that include the essential components of reading instruction.
6. Whether the eligible provider’s activities, including whether reading, writing, speaking, mathematics, and English language acquisition instruction delivered by the eligible provider, are based on the best practices derived from the most rigorous research available and appropriate, including scientifically valid research and effective educational practice.
7. Whether the eligible provider’s activities effectively use technology, services, and delivery systems, including distance education in a manner sufficient to increase the amount and quality of learning and how such technology, services, and systems lead to improved performance.
8. Whether the eligible provider’s activities provide learning in context, including through integrated education and training, so that an individual acquires the skills needed to transition to and complete postsecondary education and training programs, obtain and advance in employment leading to economic self-sufficiency, and to exercise the rights and responsibilities of citizenship.
9. Whether the eligible provider’s activities are delivered by well-trained instructors, counselors, and administrators who meet any minimum qualifications established by the State, where applicable, and who have access to high quality professional development, including through electronic means.
10. Whether the eligible provider’s activities coordinate with other available education, training, and social service resources in the community, such as by establishing strong links with elementary schools and secondary schools, postsecondary educational institutions, institutions of higher education, local workforce investment boards, one-stop centers, job training programs, and social service agencies, business, industry, labor organizations, community- based organizations, nonprofit organizations, and intermediaries, for the development of career pathways.
11. Whether the eligible provider’s activities offer flexible schedules and coordination with Federal, State, and local support services (such as childcare, transportation, mental health services, and career planning) that are necessary to enable individuals, including individuals with disabilities or other special needs, to attend and complete programs.
12. Whether the eligible provider maintains a high-quality information management system that has the capacity to report measurable participant outcomes (consistent with section 116) and to monitor program performance.
13. Whether the local areas in which the eligible provider is located have a demonstrated need for additional English language acquisition programs and civics education programs.

Programs are required to align services with Local Workforce Development Board local plans and proactively collaborate with WIOA mandatory core partners. These include Title I Adult, Youth, and Dislocated Workers, Wagner-Peyser, and Vocational Rehabilitation, and required one-stop partners.

2.2 Funds by Type

AEFLA Federal Funds – Basic Instruction

At least 82.5% of federal funds are awarded for basic instruction. All expenditures of federal funds, which may include up to 20% of federal funds for corrections education, must be allowable, reasonable and allocable in compliance with applicable federal and state law and regulations. AEFLA funds made available for adult education and literacy activities must supplement and not supplant state or local funds expended for adult education and literacy activities.

AEFLA Federal Funds- IELCE Funds

IELCE funds must be used for IELCE activities only. Expenditures of IELCE funds must be allowable, reasonable and allocable in compliance with applicable federal and state law and regulations. When necessary the costs may be determined by a reasonable method to determine the portion of costs going to IELCE. For example; the proportion of students enrolled in IELCE classes versus regular ABE, ASE, or ELL classes could be used to determine the portion of building costs charged against IELCE funds. The method used must be made clear within the budget.

State Funds

Approximately $402,000 in state funds are awarded each year and used for part of the state required match. All expenditures of state funds must be allowable, reasonable and allocable in compliance with applicable federal and state law and regulations.

Match

Nevada must match at least twenty-five percent of the total amount of funds expended for adult education and literacy activities in the state with state and local contributions, which may be in cash or in-kind; the state must then maintain the level of effort.

Local providers are required to match federal funds awarded by 25%. Match may be in-kind, or cash and all expenditures used for match must be allowable, reasonable and allocable in compliance with applicable federal and state law and regulations. Match may not include unrecovered indirect costs, other federal funds, or local or state funds used for match for a different federal grant.

Program Income Policy

CFR 200.80 defines program income as gross income earned by the subgrantee that is directly generated by a federally funded project or activity or earned as a direct result of a federal sponsored project during the period of performance. 

CFR 200.307 identifies the requirements related to program income. As summary:

• Non-federal entities are encouraged to earn income to defray program costs where appropriate. 
• Costs related to the generation of program income may be deducted from gross income as long as the costs were not directly charged to the Federal award.
• Sale of property, equipment, or supplies are not considered program income, but requirements of 200.311, 200.313 and 200.314 apply.
• Addition: Program income is added to the Federal award. This will increase the amount of the Federal award.

Program Income Requirements

• If grantees plan to collect student fees for any services provided with grant funds, the grantee must prove that the fees are necessary and reasonable.
• Fees cannot impose a barrier for students and lack of ability to pay a fee must never prevent enrollment.
• Any fee for service monies collected at the local level must be reported as “program income” and must be reinvested in the adult education program.
• Program income expenditures must be in support of the adult education programs and be allowable, reasonable and allocable in compliance with applicable federal and state law and regulations.
• Program income may not be reported as local match.
• Program income must be accounted for in program records using a separate account and using approved methods of calculating, using, reporting, and applying program income as defined in 2 CFR 200.307.
• The amount of program income earned, and the amount expended must be reported on the annual Final Financial Report (FFR) report and the supplemental FFR developed by the Office of Adult Education. Any costs associated with the generation of the program income that are not charged to the grant should be deducted from the program income earned, and the net program income should be the amount reported. 

2.3 Initial Budgets

Local providers must complete budgets for all federal funds through ePAGE. A separate budget document is required for State funds and must be uploaded into ePAGE as a part of a Continuation Funding Application or following an award notice through the competitive grant process.

When preparing the budgets, the local provider should check for the following:

1. Is the planned expenditure allowable and allocable?
2. Is there sufficient detail to determine the allowability of planned expenditures?
3. Is the budget item listed under the correct function code (i.e., administrative or instructional) and is there enough detail to verify which function code it should be under?
4. What is the non-instructional cost percentage of federal funds?
5. Does the federal budget include funds for activities that were previously paid with state or local funds, thereby supplanting?
6. If you receive IELCE funds and use a proportion of the funds for expenditures, how did you determine the proportion? Did you document this in the budget detail?

Official budget forms are posted online in ePAGE. All budgets, budget revisions and requests for reimbursement will be submitted and approved through ePAGE for federal funds.

Instructional, Support Services, and Administrative Costs

Costs that fall under the “Instruction” category are those that directly impact students. Costs for “Administration” or Non-instructional services reflect expenditures which support the instructional program; they include administrative expenses and indirect costs.

Non-instructional costs may not exceed 5% of the federal grant funding without specific approval. If 5% is too restrictive to allow for adequate planning, administration, professional development, and interagency coordination a higher rate may be negotiated with the Office of Adult Education. A “WIOA Title II Non-instructional Costs Waiver” form must be completed and submitted in ePAGE to request greater than 5% non-instructional costs.

Non-instructional costs include those costs associated with administration of the program, including supervision of faculty and staff, reporting and data entry, fiscal management, and professional development. If the program is requesting Restricted Indirect Costs, the rate approved by the institutions cognizant federal agency, or 8% as allowed under 34 CFR 76.564 must be included in the request for a higher than 5% non-instructional cost.

Non-instructional

For administration of the program, including:

• direct and indirect costs
• supervision of faculty and staff
• reporting and data entry
• fiscal management
• professional development

Salaries and fringe benefits of personnel engaged in executive activities, financial and management tasks, reporting of student data, legal or audit activities, local program monitoring, procurement, data processing, communications, and other similar functions.

Costs identifiable with program administrative positions such as the purchase of:

• materials
• supplies
• equipment
• space
• travel

Activities associated with the development of a grant application.

Instructional

Instructional costs are those associated with carrying out adult education and literacy activities. All costs associated with providing instruction for adult education students. These costs include:

• teachers’, aides’, or assistants’ salaries
• equipment for the classroom
• curriculum purchases and educational materials
• rental of classroom space

All costs associated with the development and implementation of curriculum for classroom instruction. All costs associated with the student intake and enrollment process. Activities such as:

• testing
• counseling
• student eligibility determination, including the collection of necessary information to determine eligibility
• costs associated with the placement of students in the program

Activities that are carried out by a titled administrative staff person that include:

• outreach to provide classroom space for students
• application and intake activities
• curriculum development
• other direct activities that are considered instructional in nature

High School Equivalency testing functions are unallowable costs under AEFLA (HSE preparation, however, is allowable). AEFLA funds may not be used for paying for a test or for the salary, in part or whole of HSE testing personnel or for funding professional development activities for HSE testing staff.

Allowable Costs

All expenditures submitted for reimbursement under this grant must be for proper and efficient administration of the program. An allowable cost must be reasonable (2 CFR 200.404) and allocable (2 CFR 200.405) to the Title II program and not shifted from another program or project. Allowable costs are determined by federal regulations.

Pursuant to Uniform Guidance, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards:

1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles.
2. Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items.
3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
5. Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part;
6. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also 2 CFR 200.306 Cost sharing or matching paragraph (b).
7. Be adequately documented (2 CFR 200.403).

Unallowable Costs

Unallowable costs are prohibited under Title II. Payments made for costs determined to be unallowable by either the federal awarding agency, cognizant agency for indirect costs, or pass-through entity, either as direct or indirect costs, must be refunded (including interest) to the Federal Government in accordance with instructions from the federal agency that determined the costs are unallowable unless federal statute or regulation directs otherwise (2 CFR 200.410). Explicitly disallowed costs (2 CFR 420-475) include:

1. Bad debt
2. Cost of construction or purchase of facilities or buildings
3. Lobbying
4. Sectarian worship, instruction, or proselytization
5. Light refreshments
6. Promotional items and memorabilia
7. Advertising costs that are not specifically related to the grant program
8. Commencement and convocation costs
9. Contributions and donations
10. Student activity costs unless specifically provided for in the grant award

Recognition Ceremonies

Although NDE encourages the recognition of practitioners, administrative staff, and students for their accomplishments, no AEFLA funds, including federal, state, local match, or program income, may be used for these purposes due to federal regulations.

2.4 Reimbursement Request for Funds

The federal government restricts the amount of “cash on hand” that can be kept at the state and local level. Therefore, request for funds must be submitted on a monthly basis in an amount not to exceed expenses incurred during the period.

Federal Funds (Basic and IELCE)

Requests for reimbursement of federal funds must be submitted through ePAGE and all requests must include supporting general ledger documentation. Once the Office of Adult Education receives the request it is reviewed and either approved or returned for necessary corrections. If it is returned the subgrantee will be notified and will have to resubmit once corrections are made.

After the Office of Adult Education approves the reimbursement request it goes to the Grants Office for approval before payment is made. The Office of Adult Education will not approve reimbursement without adequate detail on, or attached to, the supporting general ledger documentation. Typically, payment is made within two to four weeks after submission in ePAGE.

State Funds

Grant recipients should ensure that allowable state and local funds are spent prior to federal funds. Requests for reimbursement of state funds must be submitted on the approved form and sent to grantsinfo@doe.nv.gov . All requests must include supporting general ledger documentation. The Office of Adult Education will be notified of receipt of the request and once the request is approved it will be forwarded to the Grant Office for approval and payment. The Office of Adult Education will not approve reimbursement without adequate detail on, or attached to, the supporting general ledger documentation. Typically, payment is made within two to four weeks after it is submitted.

2.5 Budget Amendments

All budget revisions require a budget amendment. Any expenses incurred prior to approval of a budget revision may not be approved or reimbursed. Budget amendments will be accepted up to 60 days prior to the end of the subgrant award period of performance and should not occur more than once per quarter.

2.6 Final Financial Reports

Upon completion of each fiscal year, those agencies that received funding through the Adult Education and Family Literacy Act are to submit final report of expenditures of federal funds through ePAGE. A supplemental fiscal report and the FFR for state funds must be completed separately. Due dates are specified on the subgrant awards and in ePAGE.

These reports should accurately reflect the actual expenses of each project. Because funds are reimbursed there should be no funds to return, however, if there are for any reason each grant recipient will be required to return any cash on hand.

Supplemental Final Financial Report

• Program Income
  • Amount collected
  • Expenditures
  • Remaining amount
• Training Costs
  • Federal basic funds used for training
  • State funds used for training
  • Local funds used for training
  • Section 225 funds used for training
  • Section 243 funds used for training
• Career Services Costs
  • Federal basic funds used for Career Services
  • State funds used for Career Services
  • Local funds used for Career Services
  • Section 225 funds used for Career Services
  • Section 243 funds used for Career Services
• Section 243
  • Local funds used for IELCE services
• Section 225 Funds
  • Local funds used for Corrections Education
• Infrastructure Costs
  • Federal funds used for infrastructure costs
  • State funds used for infrastructure costs
  • Local or in-kind funds used for infrastructure costs
• Number of participants receiving:
  • Training services
  • Career services

Training costs are for all integrated education and training programs, including under IELCE funds.

Career Services include:

• Outreach, intake, and orientation information
• Initial assessment of skill levels including literacy, numeracy, and English language proficiency, as well as aptitudes, abilities, and supportive services needs
• Referrals to and coordination of activities with other programs and services
• Provision of performance information and program cost information on eligible providers of education, training, and workforce services by program and type of provider
• Provision of information on availability of supportive services or assistance and appropriate referrals (including childcare; child support; medical or child health assistance available through the State’s Medicaid program and CHIP; SNAP benefits; EITC; assistance under TANF, and other supportive services and transportation)

Annual Assets/Items of Value Reports

A capitalized asset purchased with state or federal funds is non-expendable property that costs more than $5,000 and has a useful life of more than one year. Items of value are those items that cost between $1,000 and $4,999.

Both capitalized assets and items of value must be reported at the end of the year on the appropriate forms. These reports should be cumulative—that is, they should reflect the program’s master inventory list of assets purchased with grant funds.

Section 3: Program Monitoring

Uniform Guidance (2 CFR 200.331) mandates that NDE conduct program monitoring of Title II programs. The purpose of monitoring is to ensure that programs use federal awards for authorized purposes in compliance with the laws, regulations, and provisions of the grant agreement and that performance goals are achieved. Programs are expected to be responsive to NDE’s, including the PD Contractor’s, technical assistance efforts, which may include meetings, workshops, and trainings. As recommendations arise from technical assistance, programs are expected to implement them in a timely manner.

Monitoring of subgrantees will include one or more of the following:

• Onsite monitoring
• Virtual monitoring
• Desk monitoring
• Targeted monitoring

3.1 Risk Assessment

During the fall of each program year the NDE will conduct an annual assessment of each WIOA Title II subgrantee to determine risk associated with funding and delivery of services. Those determined to be at significant risk will have onsite monitoring. The risk assessment developed includes the following:

1. Program did not receive AEFLA funding in the previous fiscal year.
2. The AEFLA and/or IELCE grant awards total over $500,000.
3. Addition of new services (example: ESL or IET) or expansion of services.
4. Other entities (state/federal grant managers, partner agencies, auditors, staff employed by the program, etc.) have alerted our office of potential risks.
   1. Example: Student with disabilities is told that they cannot provide accommodations because it’s too expensive. Student or other agency contacts us to let us know.
   2. Audit reports come back with findings.
   3. Fiscal office calls us with program concerns.
   4. Core partners contacts us with lack of cooperation from another title II program.
5. Program is or has been under warning/probation status within the past two years.
6. Program proposal or continuation application needed to be significantly altered due to required changes after the competition/Conditional Funding.
   1. Examples: Section of the RFP/CFA was not addressed.
   2. Conditional Funding example: past effectiveness is questionable – every month send additional report and participate in technical assistance.
7. There was a 25% or more increase or decrease in AEFLA funding from the previous program year (Including IELCE).
8. Grantee has missed the deadline for submission of more than three (3) AEFLA reports or grant requirements in the last fiscal year. Including:
   1. Continuation Funding Application
   2. Request for funds – quarterly (October 15^th, January 15^th, April 15^th, Final day for RFF per fiscal office).
   3. Final Financial Report
   4. Final Narrative Report
   5. Data Quality Report – quarterly (October 15^th, January 15^th, April 15^th, TBD).
9. 30% or less of participants made a Measurable Skill Gain.
10. The grantee did not meet at least 50% of negotiated targets. (2019-2020 will not include Table 5 targets)
    1. Targets will include all Educational Functioning Levels and employment 2^nd quarter after exit, employment 4^th quarter after exit, median earnings, and credentials obtained.
11. The program collects fees from students.
12. Program that was funded last year had turnover in the program director or key personnel within the last twelve (12) months.
    1. Key personnel would include fiscal staff, Accountability Lead, etc.
13. Agency returned 10% or more of grant funding in previous year - including IELCE, or any portion of State funds.
14. Documented concerns with the grantee’s last Final Financial Report filed.
    1. Inconsistency between Final Financial Report and final General Ledger.
    2. Inconsistency between Final Financial Report and last approved budget/revision.
15. The grantee failed to follow through with technical assistance recommendations provided by the State office in the previous fiscal year.
16. Cost per student is more than two times higher than other programs in a similar geographic area.

There is currently a separate process for Risk Assessment through the NDE Student Investment Division, Compliance Office.

3.2 Onsite Monitoring or Virtual Monitoring

Those subgrantees determined to need onsite or virtual monitoring will be contacted within 30 days of completion of the risk assessment to schedule the monitoring visit. The following components will be included for the monitoring; state staff pre-visit documentation review, subgrantee pre-visit documentation to submit, onsite evidence collection, classroom observations, and interviews with subgrantee students, staff, and administration.

Within 45 days of the monitoring visit state staff will send a report to the subgrantee with commendations, recommendations, concerns, findings (if any), and next steps. If there are findings a corrective action plan will be required. Serious findings could place the subgrantee on a Warning, Probation, or in extreme situations, a Termination Status.

Required Documentation

1. Cumulative ledger - Cumulative ledger and purchase orders showing separate accounts for the Basic Instruction funding source.
2. Signed Test Security Agreements - Signed Test Security Agreements for student assessment materials.
3. Memorandums of Understanding (MOU) and/or partnership contracts - Memorandums of Understanding (MOU) and/or partnership contracts that utilize AEFLA/IELCE funds. These include MOUs with Local Area Workforce Board.
4. Expenditures used for match - Documentation showing expenditures used for match (within the required 25% or MOE percentage and verification that funds are not being reported as match for other federal grants).
5. Program Income - Documentation showing program income and expenditures to utilize the program income.
6. Recruitment Materials - Provide all recruitment materials.
7. Professional Development Plan - Current year’s professional development plan.
8. Conflict of Interest Policy - Provide your organization's conflict of interest policy.
9. Assessment Training Verification - Verification of completed assessment training. Either provide certification or list of individuals who have taken the training if certificates aren’t provided by vendor.
10. Class Schedule - Class Schedule with class names, dates, times, duration, instructor name, and levels. (for the purpose of setting the schedule for class observations during the on-site monitoring).
11. Student Handbook
12. Employee Handbook (including EEOC Statement)
13. Sample lesson plans - Sample lesson plans for ABE & ESL – One each (ABE/ESL/Contextualized if applicable).
14. Equipment inventory - Equipment inventory and disposal of inventory records.
15. Time & Effort Reporting - One example of time and effort reporting – Provide personnel splits between funding sources and cost objectives if an employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
16. Virtual Review Tool (emailed at the time of notification)
17. Intake Form

Warning, Probation, or Termination Status (WPTS) Process

Whether as a result of a monitoring visit, desk-monitoring, or other activity, programs are subject to the following process if NDE staff have observed failure to perform the activities described in the Request for Proposals or Continuation Funding Application, or outlined in the assurances, including, but not limited to: failure to provide required reports, failure to be on track to meet the performance targets, or failure to meet the performance targets.

Any of the preceding could result in NDE placing the provider on: (1) warning status, (2) probation status, or (3) termination status. At any time, NDE may require a targeted improvement plan and/or corrective action plan. If a targeted improvement plan or corrective action plan is required NDE will work with the provider to develop the plan. Technical assistance will be provided or made available by the NDE Adult Education staff. In the event the program fails to meet the objectives of the targeted improvement plan and/or corrective action, NDE may move the provider to termination status. In the event of Probation or Termination, NDE will communicate the program status in writing to the immediate supervisor, and president, superintendent, or executive director of the sponsoring institution.

1. Warning Status- A notification of Warning Status will entail a description of the issue in question, what action is needed or if a Corrective Action Plan is required, technical assistance available, what outcome is required, and/or, possible targets for removal from Warning Status. Periodic additional reports will be required. Some issues may be quickly addressed while others may take a year or more to meet requirements to be removed from Warning Status.
2. Probation Status- Probation Status could be a result of a Warning Status which was not addressed, or the original discovery of a more serious issue. Notification of Probation Status will detail what outcome is required, and/or, possible targets for removal from Probation Status and require development of a Corrective Action Plan, participation in technical assistance, and submission of periodic reports. It could take multiple program years to address issues and be removed from Probation Status.
3. Termination Status- Programs will be placed under Termination Status based on either the egregious misuse of funds or a failure to address an issue or issues for which the program has been placed on Probation Status. Termination could include temporarily withholding funds, cutting funds, or eliminating all grant funds depending on the severity of the matter. Termination Status may be appealed through the Director of the Office of Career Readiness, Adult Learning, and Education Options.

3.3 Targeted Monitoring

Targeted monitoring is onsite or desk monitoring that is used to focus on a particular area of concern. It may be initiated by state staff or requested by a local administrator.

Targeted monitoring may be focused on:

• Compliance
  • fiscal areas
  • ADA
  • assessment
  • accountability data
• Performance

Within 45 days of targeted monitoring state staff will send a report to the subgrantee with commendations, recommendations, concerns, findings (if any), and next steps. If there are findings a corrective action plan will be required. Serious findings could place the subgrantee on a Warning, Probation, or in extreme situations, a Termination Status.

3.4 Desk Monitoring

All subgrantees will be subject to desk monitoring each program year, as well as quarterly for data validation and performance. The following types of reports are required:

Quarterly Program Report

Quarterly Program Report that checks for timely and accurate data entry, appropriate timeframes for assessments, performance data, and completeness of data collections.

Narrative Report

The narrative report describes program activities for the year. It should include responses to the following questions:

1. Describe how the Professional Development funds awarded through A.I.R. were used.
2. Analyze your program’s statistical reports and discuss your observations. Looking at outcomes by level, in which levels did the program excel? To what would you attribute the success in those levels?
   1. Did the program’s performance meet the State performance targets in the following areas? (Reference Quarterly Program Report)
      1. Measurable skill gains
      2. Percentage post tested
      3. Average Contact Hours
      4. Separation Rate before Achieving MSG
   2. How many of the negotiated targets did the program meet?
   3. Describe plans to improve performance in those levels below the negotiated targets.
3. Describe your efforts to deliver instruction at a distance.
   1. What efforts were made to recruit students?
      1. What equipment, if any, was loaned out to students?
      2. Were hotspots used? How?
   2. What support is needed to continue and expand distance education services moving forward?
4. What changes did you make, if any, to intake, orientation, or program activities for the last full program year?
5. Describe involvement with the One-Stop system and any Title II funds used to support activities or services through the One-Stop delivery system. (Include integration of activities with other adult education, career development, and employment and training activities.)
   1. Specifically address how, if necessary, infrastructure costs for the one-stop system are paid.
6. If all allocated basic funds were not expended, please explain the reason.
7. Describe successful activities and services supported with IELCE funds, including the number of adult learners served.
   1. List the occupational areas in which IELCE students participated as part of IET required under IELCE (Section 243) funding.
   2. Describe how Workforce Preparation skills were integrated into IELCE services?
   3. Describe successes in preparing and placing IELCE program participants in unsubsidized employment, especially in in-demand occupations?
   4. Describe efforts to integrate the IELCE program activities with the local workforce development system? What challenges have you encountered in attempting to integrate the IELCE program activities with the local workforce development system?
   5. If not all allocated IELCE funds were expended, please provide the reason.
8. If your program used any federal, state, or local match funds to provide services in corrections education, what was the relative rate of recidivism for criminal offenders served? Please describe the methods and factors used in calculating the rate for the program year.

Section 4: Instructional Standards and Delivery, and Student Support Services

4.1 Student Registration, Intake, and/or Orientation

Although not strictly required, the Office of Adult Education strongly encourages, and most programs utilize, a managed enrollment process, with scheduled beginning and ending dates for instruction. Using managed enrollment has been shown to increase student retention. Sessions may be scheduled according to program needs (e.g., six to ten weeks, a college semester, etc.) and are usually established around specific curricula for ABE, ESL, or HSE preparation. 

Each program must have in place an intake process that includes the following elements:

• Registration: Collect demographic information for recording in the statewide student information system. Emphasize the importance of collecting the SSN.
• Orientation: Provide information about the program to the student and, if needed, refer the student to support services within the program or through other agencies in the community. Communicate what the student can expect from the program, the expectations for student attendance, performance, assessment (pre and post), and the need to follow-up on the student for employment/post-secondary information.
• Assessment: Determine student’s educational functioning level and appropriate class/delivery method following the Nevada Adult Education Assessment Policy.
• Advising and Interview: Collect employment barriers and assist students with goal setting. Reemphasize the need for collecting the SSN.
• Class/instructional assignment.

4.2 Student Attendance

Programs should have a written attendance policy that is communicated to all students. An effective attendance policy should:

• provide clear expectations for students.
• provide clear steps for teachers to report non-compliance.
• stipulate consequences and options for students when the policy is violated.
• detail actions to be taken by administration.

4.3 Delivery of Instruction

Instruction is delivered through classes, small group instruction, and tutoring. In general:

• Instruction is delivered at community colleges, schools, community-based organizations, businesses, community buildings, prisons, jails, faith-based organizations, or anywhere students can be accommodated.
• Whenever possible instruction is year-round, from July 1 through June 30 (fiscal year).
• Instruction takes place at convenient times to enable working adults to participate and utilize available resources.
• Any cost to the student for instruction or materials must be fair, reasonable, equitable, and not present a barrier to attending.

4.4 Concurrent Enrollment

Concurrent Enrollment through Integrated Education and Training in adult education and postsecondary education is required to be an option for students in Integrated English Literacy and Civics Education. In addition, programs are encouraged to provide options for concurrent enrollment to those students not served through the IELCE program. Adult education instruction as a part of concurrent enrollment must be contextualized and integrated within the specific occupational sector, with a single set of learning objectives for both adult education instruction and postsecondary instruction.

Although concurrent enrollment must be available for IELCE, all students being served within IELCE are not required to participate in concurrent enrollment.

4.5 Distance Learning

Distance education is a formal learning activity where students and instructors are separated by geography, time, or both for the majority of the instructional period. Materials are delivered through a variety of media including, but not limited to, print, television broadcasts, computer software, web-based interaction, and other online technologies. Teachers support distance students through communication via mail, telephone, e-mail, or other web-based technologies or software.

Distance education activities have special requirements for enrollment, assessment, curriculum, and accountability. Please see the Nevada Adult Education Distance Education Policy document in Appendix B, which describes the types of activities approved for distance education and outlines the requirements and procedures for reporting distance education contact hours.

4.6 Standards

OCTAE emphasized the importance of content standards by requiring that states describe how they align their content standards for adult education with the “State-adopted challenging academic content standards, as adopted under section 1111(b)(1) of the Elementary and Secondary Education Act of 1965, as amended (20 U.S.C. 6311(b)(1)).” Through alignment with the national College and Career Readiness Standards for Adult Education, the Nevada Adult Education Standards are aligned with the Nevada State Standards for K12.

4.7 Essential Components of Reading Instruction

WIOA (section 231 (e)) requires that states consider the extent to which an eligible provider uses instructional practices that include the essential components of reading instruction in awarding Title II grants. The Adult Education and Family Literacy Act (Title II) states that the term “essential components of reading instruction” has the meaning given the term in section 1208 of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 6368) which is explicit and systematic instruction in:

• phonemic awareness
• phonics
• vocabulary development
• reading fluency, including oral reading skills
• reading comprehension strategies

4.8 Service to Students with Special Needs

AEFLA-funded programs will provide reasonable accommodations, as required by ADA and other federal and state laws, to those adults with disabilities. “Special needs” is a broad term that incorporates the need for some type of accommodation. For example, students with special needs may have a physical disability, a learning disability, or a developmental disability.

1. Programs must provide fully accessible services and ensure that these services meet reasonable criteria according to federal and state law and the policies of their organization.
2. Programs must require that adult students with disabilities are responsible for requesting accommodations and for submitting documentation of their disability.
3. Programs must follow their organization’s policy regarding services to individuals with disabilities.
4. Programs must provide accommodations at no cost to the student.
5. Programs must provide students with the same disabilities services as other individuals receiving educational services in the organization, including assessment, counseling, advising, and provision of reasonable accommodations, assistive technology, and other accommodations available to other students.
6. Programs must provide the same accommodations for testing as they do for instruction.

4.9 Reasonable Progress

A student with a documented disability must demonstrate progress toward an "appropriate" goal. If the student cannot or does not demonstrate progress, the program should have a record of the student’s identified goal(s), plan for achieving the goal(s), monitoring of progress, etc. It is not unreasonable for a program to emphasize that adult education is an education program and participation in the program requires measurable education or workforce readiness progress.

For students with a documented disability, to ensure programs are not being discriminatory, there must be reasonable accommodations regarding scheduling and assignment formats. However, if the student is still showing no learning gains, even on teacher-constructed tests, end-of-chapter tests, etc., then the student (and perhaps an advocate) needs to be informed that unless measurable progress toward a goal is made by a defined future date, then the student will no longer be a participant in the program because the program is not appropriate for this student.

When this process is followed, students have been given due process, programs have not been discriminatory, and the program has followed a consistent process that documents that concerted efforts were made to help the student meet education and workplace readiness goal(s). If a student is not making measurable progress and the elements listed above are in place, including reasonable accommodations, the adult education program may not be appropriate for the student. The program must have a very consistent process that is used with each and every student. When a consistent process is followed with every student, the program should have documentation that confirms that the program is, or is not, an appropriate placement for the student. For example, if a student is not making progress because of excessive absences, the program will have a record of the student’s attendance, a record of contact with the student explaining the necessity for consistent attendance and consistent effort for the student to achieve their goal(s). With this documentation, it is not unreasonable to remove a student when the student obviously does not (cannot or will not) meet the program's reasonable expectations leading to goal attainment.

Student handbooks and other orientation materials should state very clearly the expectations of the program; that all students will identify and work toward an appropriate education or workforce readiness goal and those students will demonstrate ongoing measurable progress.

Section 5:  Staffing and Professional Development

5.1 Staffing

Although there are no statewide requirements for hiring or evaluating instructors and tutors, as part of ongoing statewide program improvement efforts, program directors are encouraged to follow several effective practices:

• Programs are strongly encouraged to develop clear position descriptions for instructional and administrative staff.
• Programs should require all practitioners who are new to adult education in Nevada to complete the state’s online pre-service training and turn in the coursework to the program administrator prior to beginning instruction.
• Programs should encourage all practitioners and staff to participate in quality staff development opportunities, be they local, regional, or national.
• Programs are strongly encouraged to provide stipends for staff development.
• Programs are strongly encouraged to implement a process for regular evaluation.

5.2 State Leadership Funded Professional Development

Using not more than 12.5 percent of the grant funds to carry out State Leadership activities, NDE allocates funds for the following required adult education and literacy activities:

1. The alignment of adult education and literacy activities with other core programs and one-stop partners, including eligible providers, to implement the strategy identified in the Nevada WIOA Unified State plan, including the development of career pathways to provide access to employment and training services for individuals in adult education and literacy activities.
2. The establishment or operation of high quality professional development programs to improve the instruction provided pursuant to local activities required under WIOA section 231(b), including instruction incorporating the essential components of reading instruction as such components relate to adults, instruction related to the specific needs of adult students, instruction provided by volunteers or by personnel of a State or outlying area, and dissemination of information about models and promising practices related to such programs.
3. The provision of technical assistance to eligible providers of adult education and literacy activities receiving funds under this title, including— (i) the development and dissemination of instructional and programmatic practices based on the most rigorous or scientifically valid research available and appropriate, in reading, writing, speaking, mathematics, English language acquisition programs, distance education, and staff training; (ii) the role of eligible providers as a one-stop partner to provide access to employment, education, and training services; and (iii) assistance in the use of technology, including for staff training, to eligible providers, especially the use of technology to improve system efficiencies.
4. The monitoring and evaluation of the quality of, and the improvement in, adult education and literacy activities and the dissemination of information about models and proven or promising practices within the State.

State Leadership funds may also be used for the following permissible activities:

1. The support of State or regional networks of literacy resource centers.
2. The development and implementation of technology applications, translation technology, or distance education, including professional development to support the use of instructional technology.
3. Developing and disseminating curricula, including curricula incorporating the essential components of reading instruction as such components relate to adults.
4. Developing content and models for integrated education and training and career pathways.
5. The provision of assistance to eligible providers in developing and implementing programs that achieve the objectives of this title and in measuring the progress of those programs in achieving such objectives, including meeting the State adjusted levels of performance described in WIOA section 116(b)(3).
6. The development and implementation of a system to assist in the transition from adult education to postsecondary education, including linkages with postsecondary educational institutions or institutions of higher education.
7. Integration of literacy and English language instruction with occupational skill training, including promoting linkages with employers.
8. Activities to promote workplace adult education and literacy activities.
9. Identifying curriculum frameworks and aligning rigorous content standards that:
   1. specify what adult students should know and be able to do in the areas of reading and language arts, mathematics, and English language acquisition; and
   2. take into consideration the following:
      1. State adopted academic standards.
      2. The current adult skills and literacy assessments used in the State or outlying area.
      3. The primary indicators of performance described in WIOA section 116. (WIOA Title II)
      4. Standards and academic requirements for enrollment in non-remedial, for-credit courses in postsecondary educational institutions or institutions of higher education supported by the State or outlying area.
      5. Where appropriate, the content of occupational and industry skill standards widely used by business and industry in the State or outlying area.
10. Developing and piloting of strategies for improving teacher quality and retention.
11. The development and implementation of programs and services to meet the needs of adult students with learning disabilities or English language students, which may include new and promising assessment tools and strategies that are based on scientifically valid research, where appropriate, and identify the needs and capture the gains of such students at the lowest achievement levels.
12. Outreach to instructors, students, and employers.
13. Other activities of statewide significance that promote the purpose of WIOA Title II.

Implementation of a professional development system funded by AEFLA leadership dollars and formed through a competitive contract awarded to the American Institutes for Research (A.I.R.), began in September of 2017. The contract provides multiple professional development and technical assistance events throughout the program year.

5.3 Nevada Adult Education Teacher Orientation

The Nevada Adult Education Teacher Orientation online course was developed by A.I.R. through a contract with the Nevada Department of Education. Administrators are responsible to ensure that new teachers complete the online course. Current or returning teachers are encouraged to complete the course. Teachers interested in taking this course should send their name, program and agency name, and preferred email address to nevadaadultedpdtechsupport@air.org. In the subject line of the message, teachers should write “Enrollment request, Nevada Adult Education Teacher Orientation”. Within one business day, teachers will receive individual log-in instructions. Programs should maintain the Certificate of Completion for each teacher completing the course and retain based on the appropriate retention schedule.

5.4 Required Professional Development for AEFLA Staff

The following chart shows the required PD for AEFLA Staff by role. Trainings are largely available at www.nevadaadulteducation.org. Confirmation of adherence to required PD will be determined through monitoring.

Training		Delivery	How often?
Administrators	New Director Training - where to find our website, partner websites, handbook, technology, teacher and admin resources, past webinars.	One on one with NDE Staff	Within first 3 months of employment
	Nevada Adult Education Teacher Orientation Online Course	Online	Within first 6 months of employment
	Introduction to Adult Education Standards	Online	Within first 6 months of employment
	LACES Trainings - review old ones and attend new ones	Webinar/in-person Literacy Pro	2-3 webinars per year/1 in-person when possible
	Director Meetings	Webinar/in-person	In-person 2 statewide and 1 regional for two regions/or short webinars with targeted content
	Nevada AEFLA Shop Talk	Webinar	Bimonthly
	NRS (National Reporting System) Online Courses - Modules A - F	NRS Online	Minimum of once during the first 6 months
Assessment	TABE 11/12	DRC - workbook/ DVD/ Webinar	All assessment personnel using TABE - Every two years
	TABE CLAS-E	DRC - workbook/ DVD/ Webinar	All assessment personnel using TABE - Every two years
	CASAS (Life and Works - Listening & Reading) - All ESL	CASAS Online	All assessment personnel using CASAS - Every two years
	CASAS (GOALS Reading & Math) - All ABE/ASE	CASAS Online	All assessment personnel using CASAS - Every two years
Instructors	Nevada Adult Education Teacher Orientation Online Course	Online	Minimum of once during the first 6 months
	Introduction to Adult Education Standards	Online	Within first 6 months of employment
Data	Nevada Adult Education Teacher Orientation Online Course	Online	Minimum of once during the first 6 months
	Nevada LACES Users Group (NLUG)	Webinar	Quarterly
	LACES Trainings - review old ones and attend new ones	Webinar/in-person Literacy Pro	2-3 webinars per year/1 in-person when possible
	NRS (National Reporting System) Online Courses - Modules A - F	NRS Online	Minimum of once during the first 6 months

Section 6:  Accountability: Data Collection and Reporting

The National Reporting System (NRS) defines a set of measures that describes adult education students, their participation, and the outcomes that they achieve. The State of Nevada is responsible for implementing NRS measures, methods, and requirements in a way that meet Federal guidelines; providing resources, training, and support for data collection to local programs; monitoring local programs using quality control procedures to ensure data validity; and maintaining a database that includes data from all local programs.

To ensure compliance with federal legislation and regulations, state policies and procedures, the requirements of the NRS, and the NRS Data Quality Standards for Adult Education, all adult education programs funded through the Adult Education and Family Literacy Act (AEFLA) are required to collect and accurately record student data as described in this section of the handbook.

6.1 Student Privacy

The benefits of using student data must always be balanced with the need to protect students’ privacy rights. Students should expect that their personal information is safe, properly collected and maintained and that it is used only for appropriate purposes and not improperly re-disclosed. It is imperative to protect students’ privacy to avoid discrimination, identity theft or other malicious and damaging criminal acts. All education data holders must act responsibly and be held accountable for safeguarding students’ personally identifiable information. Programs are responsible to comply with all federal and state regulations regarding student data.

Informed consent

All students should sign an Informed Consent form. The form may be signed one of three ways by the student:

1. Students provides SSN and signs the form (preferred),
2. Student does not provide SSN, but signs the form to as an acknowledgement of the follow-up process, or
3. The student does not provide SSN and refuses to sign.

Based on the student response, the data must be recorded in LACES by selecting either “Yes”, “No”, or “No Value Entered” under the “Data Sharing Agreed” dropdown in the Student Data tab. No Value Entered should only be used when no response has been provided by the student. “No” should be entered when the student refuses to share information.

Programs may use customized versions of the Informed Consent Form providing the version includes all data from the state form.

For a sample informed consent form, follow this link [PDF].

6.2 Management Information System

Nevada AEFLA funded programs are required to use LiteracyPro Systems, Inc. LACES application to place students, track progress, and produce quarterly and annual reports.

Data Entry

Best practice for all data entry is that the data in question is entered within one week of collection. Programs will be allowed up to two weeks at a maximum to enter all data such as new student registrations, assessments, attendance, and follow-up survey responses.

Student Attendance

A record of attendance must be kept for every student enrolled with the following information:

• Student name and/or student identification number
• Class identification number
• Date of attendance
• Student daily hours of attendance

Programs may optionally include other information such as pre- and post-test scores on this record. All students with demographic information entered will be counted as a “WIOA Reportable Individual” for federal reporting purposes. Students with 12 or more hours and a pre-assessment will be counted as a “WIOA Participant” and will be subject to outcome measures. Attendance records are subject to the record retention policy.

Attendance may be entered directly into LACES or uploaded into LACES from another tracking program.

Personnel

For federal reporting purposes, every staff member directly involved with grant funded activities must have a staff record in LACES.

6.3 Record Retention

All student records, be they paper or electronic, must be kept in such a manner as to be easily accessible for a minimum of 36 months after the date of the final report of expenditures for each fiscal year. The rule of thumb is to retain records for five years; this ensures that the minimum retention period is met. When original records are electronic and cannot be altered, there is no need to create and retain paper copies. When original records are paper, electronic versions may be substituted through the use of duplication or other forms of electronic media provided that they are subject to periodic quality control reviews, provide reasonable safeguards against alteration, and remain readable.

6.4 Performance Measures – Reporting/Accountability

The Nevada Unified State Plan proposes an accountability system of student outcomes based on collected data including these primary indicators of performance as stipulated in WIOA Section 116(b), and as they apply to the AEFLA program:

• Employment, 2nd quarter after exit
• Median Earnings, 2nd quarter after exit
• Employment, 4th quarter after exit
• Measurable Skills Gain
• Credential Attainment
• Effectiveness in serving employers

Core Performance Outcomes Definitions and Criteria:

Outcome: Measurable Skill Gain

Denominator (Cohort): All participants

Numerator: Total number of participants achieving a measurable skill gain.

Definition of Outcome:

1. Participant completes or advances one or more educational functioning levels from the starting level measured on entry into the program.
   1. There are four levels for adult basic education (ABE), two for adult secondary education (ASE), and six levels of ESL.
   2. The program decides the skill areas in which to assess the student based on the student’s instructional needs.
2. The participant exits the adult education program and enters postsecondary education within the same program year.
3. A student at any entry level who achieves attainment of their high school equivalency.
4. Participants in IET or workplace literacy programs can demonstrate MSG by exhibiting progress on a secondary or postsecondary transcript, showing progress toward milestones, or passing a technical/occupational knowledge–based exam. However, these measures cannot be used to report MSG for adult education participants who are not enrolled in workplace literacy and IET.

Follow-up Measure #1: Employment Rate 2nd Quarter after Exit

Denominator (Cohort): Total number of participants who exit during the program year.

Numerator: The percentage of participants who are in unsubsidized employment during the second quarter after exit from the program.

Definition of Outcome: The number of participants who exited during the reporting period who are found to be employed, either through direct UI wage record match, federal or military employment records, or supplemental wage information, in the second quarter after the exit quarter. The exit quarter is the quarter when the participant terminates or has not received instruction for 90 days and is not scheduled to receive further instruction.

Process for Determining Outcome:

• Employment is working in a paid, unsubsidized job or working 15 hours or more per week in an unpaid job on a farm or business operated by a family member or the student.
• Outcome is primarily determined through data matching at the state level.
• Outcome may be determined by supplemental wage survey conducted at the local level.

Follow-up Measure #2: Median Earnings 2nd Quarter After Exit

Definition of Outcome: The median earnings for all participants employed in the second quarter after exit.

Process for determining outcome:

Total quarterly earnings, for all participants employed in the second quarter after exit, are collected by either direct wage record match or supplemental wage information. The collected quarterly wage information values are listed in order, from the lowest to the highest value. The value in the middle of this list is the median earnings value, where there is the same quantity of numbers above the median number as there is below the median number. Funding is based on the number of exited participants whose earnings are greater than or equal to the state median wage.

Follow-up Measure #3: Employment Rate 4th Quarter after Exit

Denominator (Cohort): Total number of participants who exit during the program year.

Numerator: The number of participants who are in unsubsidized employment during the fourth quarter after exit from the program.

Definition of Outcome: The number of participants who exited during the reporting period who are found to be employed, either through direct UI wage record match, federal or military employment records, or supplemental wage information, in the fourth quarter after the exit quarter. The exit quarter is the quarter when the participant terminates or has not received instruction for 90 days, and is not scheduled to receive further instruction.

Process for Determining Outcome:

• Employment is working in a paid, unsubsidized job or working 15 hours or more per week in an unpaid job on a farm or business operated by a family member or the student.
• Outcome is primarily determined through data matching at the state level.
• Outcome may be determined by supplemental wage survey conducted at the local level.

Follow-up Measure #4: Credential Attainment

Denominator (Cohort): All participants who exited during the program year and were in either a postsecondary education or training program OR in a secondary education program at or above the 9th grade level without a secondary school diploma or its equivalent.

Numerator: The number of participants who exited during the reporting period who obtained a recognized postsecondary credential during the program or within one year after exit OR those who were in a secondary education program and obtained a secondary school diploma or its recognized equivalent during the program or within one year after exit and were also employed, or in an education or training program leading to a recognized postsecondary credential within one year after exit.

Process for Determining Outcome:

• Follow-up surveys and/or state level data match are used to determine attainment of a recognized postsecondary credential.
• State level data match is the primary method used to determine attainment of a secondary school diploma or its recognized equivalent and subsequent enrollment into postsecondary education or training or entry into employment.
• For this measure a follow-up survey may be used to determine entry into postsecondary education or entry into employment for individuals who have received a secondary school diploma or its recognized equivalent.

Follow-up Measure #5: Effectiveness in Serving Employers

Retention (Retention with the same employer): Percentage of participants who are employed at the same employer in the second and fourth quarters. Repeat Business Customers: Percentage of employers who receive services that use core program services more than once.

Process for Determining Outcome:

• Outcome is primarily determined through data matching at the state level.
• Outcome may be determined using data collected through the supplemental wage survey conducted at the local level.