Massachusetts Policies for Effective

Workplace Education Partnerships

FY2018 - FY2022

Adult and Community Learning Services75 Pleasant Street

Malden, MA 02148-4906www.doe.mass.edu/acls

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Table of Contents

Introduction.................................................................................................................................................4Overview and Purpose of Workplace Education.........................................................................................4Connections with the Local Workforce Development Board.......................................................................4

PHASE ONE: PLANNING.............................................................................................................................................The Workplace Needs Assessment (WNA).................................................................................................5

Process and Purpose...............................................................................................................................5The WNA Team.......................................................................................................................................6WNA Tools and Methods........................................................................................................................6The WNA Report.....................................................................................................................................7

PHASE TWO: IMPLEMENTATION.........................................................................................................................The Planning and Evaluation Team (PET)...................................................................................................7

Function and Roles..................................................................................................................................7Initial Work.............................................................................................................................................8Ongoing Delivery of Instructional Services..............................................................................................8

Roles and Responsibilities..........................................................................................................................9The Education Provider...........................................................................................................................9The Workplace Education Coordinator...................................................................................................9The Business............................................................................................................................................9The Union..............................................................................................................................................10The Teacher..........................................................................................................................................10The Students.........................................................................................................................................10Recruitment of Participants..................................................................................................................10

Program Design.........................................................................................................................................11Class Design and Hours.........................................................................................................................11Release Time.........................................................................................................................................11Calculating the Workplace Coordination Hours....................................................................................12Paid Class Preparation Time for Teachers (prep)..................................................................................13Professional Development for Teachers................................................................................................13

Instruction.................................................................................................................................................13Contextualizing Curriculum...................................................................................................................13Formative Assessment..........................................................................................................................15Summative Assessment........................................................................................................................16

Assessment Policies..................................................................................................................................16Assessment Policy 1: Three Assessments in a Fiscal Year......................................................................16Assessment Policy 2: Primary Assessment Area (PAA)..........................................................................16Assessment Policy 3: Pre- and Post-Testing..........................................................................................17Assessment Policy 4: Copy-Over of Assessments and the Shelf Life of a Test........................................18Assessment Policy 5: Pre- and Post- Assessment Targets......................................................................18Assessment Policy 6: Student Placement..............................................................................................18Assessment Policy 7: Reporting Assessments in the SMARTT Database...............................................18Assessment Policy 8: Training and Certification of Test Administrators................................................19

Measurable Skills Gain (MSG) and Performance Accountability..............................................................19MSG Benchmarks and Targets..............................................................................................................19

Fiscal and Data Accountability..................................................................................................................20Record Keeping....................................................................................................................................20Administrative Costs.............................................................................................................................20Restrictions...........................................................................................................................................20Salaries and Benefits.............................................................................................................................20

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Matching Funds....................................................................................................................................21No Charges to Students Students should receive instructional materials at no cost.............................21Materials and Supplies including Computing Devices...........................................................................21Control of Computing Devices and Equipment......................................................................................21Disposal of Computing Devices and Equipment....................................................................................22Code of Federal Regulations.................................................................................................................22Statement of Assurances (SOA).............................................................................................................22Risk Management.................................................................................................................................22Financial Audit Requirement.................................................................................................................22

Fiscal Responsibilities...............................................................................................................................23Indirect Costs........................................................................................................................................23Time and Effort Reporting.....................................................................................................................23

General Administration............................................................................................................................23Requests for Funds................................................................................................................................24Amendments.........................................................................................................................................24Unexpended Funds................................................................................................................................24Condition of Funding.............................................................................................................................24Record Keeping.....................................................................................................................................25

Data Quality and Integrity........................................................................................................................25Attendance............................................................................................................................................25SMARTT Data Entry...............................................................................................................................25Data Lock-out and Data Lock-out Schedule..........................................................................................25Follow-up for Federal WIOA Measures.................................................................................................26Follow-up and Automatic Exit Schedule................................................................................................26

APPENDIX A................................................................................................................................................................. 28Alignment with Local Plan Packages.........................................................................................................28Template...................................................................................................................................................28

Introduction

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Workplace education is a vibrant component of the Adult Education (AE) service delivery system managed by Adult and Community Learning Services (ACLS) at the Massachusetts Department of Elementary and Secondary Education (ESE). Recognizing that the quality of the workforce is their competitive edge, business leaders realize that they cannot let worker skills become outdated. Enhancing worker skills is the way to retain relevance in a marketplace that is increasingly competitive and located in a state that depends on a highly skilled workforce. By offering basic skills instruction integrated with work-related content, workplace education programs provide benefits for both the worker and the employer. Worker/students are engaged more effectively and their skills become more immediately relevant, thereby increasing their potential for job advancement.

AE in Massachusetts consists of Community Adult Learning Centers, workforce partners and other entities working together to create a strong, unified, and effective system for adult learners seeking greater opportunities for themselves, their families, and their communities.

Overview and Purpose of Workplace Education Workplace education grants funded by ACLS provide support to education providers, in partnership with businesses and labor organizations, to meet current and escalating skill demands on the incumbent workforce. Workplace education programs represent a state strategy to locate and serve undereducated adults in familiar contexts. Offering classes at the workplace increases the possibility of fitting learning into adults’ busy schedules. Education programs at the workplace provide workers with contextualized language, literacy, and related skills instruction so they can maintain employment, advance on the job, and interact more fully in their work, family, and community lives.

Grants are awarded to provide instructional services at the workplace to those with skills below the postsecondary level, from basic literacy or beginning English language proficiency through the skill level expected of a high school graduate. Each workplace, however, presents its own set of language and literacy needs depending on its employee population; workplace education classes are custom designed to meet these needs.

Workplace education programs are funded in two phases. These guidelines illustrate the activities expected to take place in each of the two phases.

Connections with the Local Workforce Development BoardEach workplace education provider must establish connections with and provide evidence of outreach to the local workforce development board (WDB) in the local workforce development region (WDR) where the business partner is located and demonstrate alignment with the local WDB plans.

PHASE ONE: PLANNINGThe Workplace Needs Assessment (WNA)Process and Purpose Once the education provider identifies a committed business partner together they will need to explore the existing possibilities for a workplace education program. This is to be accomplished by conducting a planning process called the workplace needs analysis (WNA). ACLS requires an ethnographic approach to the planning process. There are some practical reasons for employing an ethnographic approach. Indeed, from the moment an educational provider sets foot in a workplace, she or he has entered an unknown environment – one with its own culture, set of expectations, workplace processes and decision-making, and its own formal and informal communication system. Ethnography has its roots in anthropology, and has applications that lend themselves to learning about organizations and their complex pattern of norms, attitudes, beliefs, behaviors and traditions that are frequently deeply engrained in a workplace. The educational

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provider must embark upon an investigatory process to learn about these in the workplace environment in order to understand the setting of a multi-year program of classroom instruction and to be confident sufficient assets exist for its success.

For example, interviewing workers using an ethnographic approach is a way of eliciting information from them that respects their experience of the workplace, rather than the workplace culture of the interviewer.

Principles of Ethnography that apply to the WNA process include: structure the time to hear concerns of workers. maintain the objectivity of an outsider. This means that WNA team members keep open

minds as they explore what is needed in the workplace; the observer has no vested interest in the outcomes.

assure/maintain confidentiality. create ways to understand the cultural values and norms (written and unwritten) of the

workplace. For example create some open-ended questions to give the workers freedom to express themselves. Pay close attention to language used and the examples provided during the information part of the WNA.

Through data collection activities, encourage WNA participants to express their own perspectives and record these as such.1 This process, which typically takes three months, allows stakeholders, in a neutral manner, to investigate the educational needs within the organization and identify the organizational assets needed to support an education program.

The partnership engages in a WNA which includes the following: analyzes the overall educational needs of workers within a business/union/organization; looks for potential assets to the success of the workplace education and determines

strategies to capitalize on these; looks for potential barriers to the success of the workplace education program and

develops strategies to overcome potential barriers to the program; evaluates the language, literacy, and numeracy skills needed for the range of job

categories; examines oral and written communication systems of the workplace, including use of

workers’ first languages, bilingual resources, and how workers perform their jobs; investigates the readiness of the partnership to sustain a multi-year basic education

program; and plans for Phase 2 components, including classroom space.

The WNA Team The education provider provides the lead person to spearhead and oversee all phases of the WNA. In most cases, the WNA team is comprised of a small but active group. Depending on the size of the business and the number of departments and/or shifts to potentially be part of the education program, the WNA team typically includes a teacher, a workplace education coordinator and one or two representatives from both the business and union, where the

1 Some ethnographic principles mean we put aside our own assumptions, start without hypotheses and listen to the language of the interviewees.

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workforce is unionized. The members will need time to plan as a team and to individually carry out certain tasks. Others may be included in the process as needed. The WNA team determines a method of introducing the WNA process and goals to the workforce. At this early stage, the WNA team clarifies its purpose to the larger workforce and identifies data collection activities. Most teams will consider data collection options such as focus groups, one-on-one interviews, written surveys, questionnaires or online surveys.

It is essential that the WNA team ensures all feedback is kept confidential and communicates the policy of confidentiality to the workforce. No classes should be promised at the start of the planning process. This initial step may help to dispel uneasiness when the process to elicit input from work groups begins. The information collected will determine the readiness of the business to establish an education program and will ultimately be used to design a strong program.

WNA Tools and MethodsParticipation in the WNA should be voluntary, and potential students involved should represent a cross section of the departments targeted for the education program. This includes age, gender, ethnicity, work shifts, and first languages. A thorough WNA:

includes a representative sampling of the workforce (10% - 20%) to ensure a variety of perspectives, e.g., employees, supervisors, senior management, union membership (where workforce is unionized), human resources and education and training personnel) throughout the WNA;

examines the resources within an organization, including other education and training programs, tuition reimbursements, and related benefits that can expand the scope of a workplace education program;

researches the educational goals of the potential students; gathers a preliminary assessment of the basic skill needs of the potential students; and researches the skills workers need for advancement.

A variety of tools and methods are needed to elicit input for an effective WNA. The selection of data collection tools, i.e., questionnaires, one on one interviews, surveys, focus groups—will differ depending on many factors. Such factors include the scope of the program, the number of workers to be involved, the various language groups, level of trust among worker groups and the access the WNA team has to the staff. WNA team members determine if some documents should be translated into the first languages of workers if some have limited English skills. Not all of the suggested data collection protocols or tools listed are necessary for every WNA; each WNA team develops the tools appropriate to their needs.

A literacy task analysis may or may not be conducted as part of the WNA. A literacy task analysis determines the literacy and related basic skills required for tasks (reading a code or inputting data, for example) in a job. The WNA may use the resulting inventory to identify gaps, where workers need skills upgrading. A literacy task analysis can give a broad view of jobs or a detailed account of a job. It may also examine a few key tasks. As information for curriculum development, it fits well with workplace education where knowledge and skills are taught in a sequence. To set the scope of a literacy task analysis, the WNA team must know the purpose and how this information will be used. A WNA team may need a less formal description of tasks rather than extensive data to be analyzed and summarized. If selected as an activity, the WNA team must determine the appropriate breadth and depth of their literacy task analysis.

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A job task analysis, generally a more formal and rigorous assessment of the requisite knowledge, skills and abilities may or may not be part of the WNA. A job task analysis may consider how frequent a certain type of task is performed and how critical the task is to overall job performance. Again, the WNA team must determine the appropriate breadth and depth of a job task analysis if this they choose to take this on.

Finally, each stakeholder must understand what can and cannot be achieved by an educational program. This shared knowledge is critical in developing a solid foundation for a successful workplace education program. The WNA should identify problems that cannot be mitigated by a workplace education program, i.e., what issues exist that a workplace education program can and cannot remedy.

The WNA ReportThe data collected during the WNA is analyzed and reviewed by the WNA team for accuracy. If the results of the WNA yield recommendations for an education program, the report will include:

a program design with the type of class(es) to be offered, i.e., ABE, English to Speakers of Other Languages (ESOL), writing, math;

a class schedule (dates, times, hours per week, weeks per year) and number of students per class; and

A Memorandum of Agreement (MOA) signed by all stakeholders and that reflects the business commitment to the partnership.

PHASE TWO: IMPLEMENTATIONThe Planning and Evaluation Team (PET)Function and RolesBecause numerous stakeholders are invested in a workplace education program, a team governance approach has been an essential component of the Massachusetts workplace education model for many years. Establishing a PET, whose members meet and communicate regularly, serves multiple functions, including:

designing goals and outcomes for the program; identifying and removing barriers to employee participation in class(es); identifying and documenting student achievement and successes; and providing input for formative and summative evaluations.

The PET includes representatives from management, labor, and education. Each partnership selects its PET members strategically, considering the following: Who is most invested in the program and available to attend meetings? Who has decision making authority? Who can serve as a “champion” to the program helping to generate enthusiasm and support from supervisors, employees, and other staff? A strategic selection of PET members helps promote program ownership and ensure high quality services.

As part of its work, a successful WNA team will have identified business and labor partners who have shown a deep interest in and commitment to the goals of the workplace education program. Formerly active members of the WNA team may volunteer for or be invited to form the PET.

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Teachers should participate in PET meetings and visit the students’ workplaces to observe and collect materials for classroom instruction.

Frequently students have a role on the PET as well. At least one student from each class is encouraged to participate in PET meetings. Participation in team meetings provides students with leadership skills, helps them practice business discourse, and allows them a glimpse of management and facilitation strategies. The student representatives can elicit concerns and opinions of students in the class and voice them at meetings. Teachers can help student representatives prepare for the PET meetings by using role-plays in class where student representatives receive coaching in contributing feedback and become familiar with the conventions of business meetings. As such, participation in the PET becomes another workplace skill—in some cases, one that adds to an employee’s chance for advancement.

Initial WorkInitial PET meetings may focus on the logistics of program start-up:

setting an agenda and schedule of PET meetings; identifying class participants; developing wait list policies and attendance policies to ensure equitable access to the

education program; determining who will be eligible to attend classes(es); planning and scheduling orientations to the program; notifying supervisors and potential students of openings in the class(es); resolving work coverage issues for enrolled students, and identifying strategies for input into the curriculum and instruction.

Ongoing Delivery of Instructional Services As the program continues, the face-to-face PET meetings may occur monthly, every six weeks or as frequently as needed to ensure the program is running efficiently. The number of meetings is often correlated to the simplicity or complexity of the program design. For example, the number of departments involved in the program usually increases the involvement of the number of supervisors and managers. If the workforce is unionized, union representation is an additional stakeholder. The importance of regular face-to-face meetings cannot be overstated. On an on-going basis, the PET should focus on development of the program. Is the program on track? How does the PET know that program goals are being met? What adjustments may be made to improve the program? What workplace themes should be addressed in the program’s curriculum? What are some tools and strategies to evaluate the program and the effectiveness of the PET itself? How can the PET share successes while maintaining confidentiality of individual assessment results and student progress?

Roles and ResponsibilitiesThe Education ProviderAs the grant recipient, the education provider is expected to hire, train, and supervise the workplace education program staff. These staff include the workplace education coordinator and teachers who bring educational expertise to the partnership. The education provider is responsible for fiscal oversight and ensures that expenditures are allowable and appropriate and that allocated funds are available throughout the fiscal year. The education provider is responsible for all required ACLS data entry and reports.

The Workplace Education Coordinator

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The workplace education coordinator role requires strong organization and team facilitation skills to meet and collaborate with a diverse stakeholder groups in order to deliver a high quality educational program. The workplace education coordinator develops a vision for and brings leadership to the project. Typically the responsibilities are far reaching as the coordinator helps the PET to clarify expectations and goals but often negotiates other issues as these may arise with the business representatives. The coordinator is responsible to lead the PET through the cycles of program planning and program evaluation and to ensure the work is documented. In addition, as the convener and leader of the PET, the coordinator often serves as the liaison between ACLS and the program.

Additionally, the Coordinator: orients the PET to its roles and responsibilities; convenes regular PET meetings; maintains records/minutes of PET meetings; provides staff supervision including regular teaching evaluations and classroom

observations with written feedback and follow up; ensures that the curricula and instructional methodologies for mathematics/numeracy,

reading, writing, and second language acquisition are based on a solid foundation of research and effective practice, including research in adult learning and development as well as research in content-specific pedagogy;

ensures that current and appropriate technologies are incorporated into curriculum and instruction, and

ensures enrollment and excellent class attendance.The Business Managers, supervisors and often human resources staff are excellent choices as representatives on the PET. All members must believe in the value of the program and commit to attend meetings. Members will need to help solve problems as they arise. The business partner supplies the classroom space. This space should be quiet, equipped with table(s), chairs, good lighting, and good ventilation. Often, classes are held in conference or training rooms or in sections of a cafeteria during non-operational hours. Whatever space is designated as a classroom should be consistently available. (The disposition of the classroom space issue should be an outcome of the WNA.) It is helpful for the teaching staff if the business also provides secure storage space for instructional equipment and supplies, such as a whiteboard, markers, newsprint, books, and computers. Because the education program is contextualized, the employer supports the development of customized and contextualized curricula by providing the coordinator/instructor with access to the business, especially in departments where the students are working. When instructors are able to observe the language, oral and written and communication and math required of their students, they can translate those needs into effective teaching materials.

The Union Unions play an important role in workplace education programs. The union partner should select a representative—for example, business agent, steward, local president—to serve on the PET. Like the business partner, a union representative should be available and committed to the success of the program. The unions, for example, can play an active role in recruiting students for the program. Union newsletters, often translated into the home languages of the union members, can describe the classes and invite workers to participate.

The union representative can provide useful literacy materials—such as copies of the union contract and flyers about union meetings—as a basis for instructional materials. The union member is a valuable resource for teachers about workplace rights, safety and health protections,

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and procedures for taking full advantage of workplace protections and benefits under a union contract.

The TeacherTeachers can create work-related lessons from PET requests. Teachers incorporate work-related materials into their language, reading, writing, and math classes in many different ways.

In addition to handling PET expectations, teachers use a variety of activities and methodologies to discover the workplace education language and literacy needs and themes of interest to the students. PETs, however, vary in their involvement from partnership to partnership. Sometimes they are a major source of work-related curriculum. Other PETs are supportive but largely “hands off” in curriculum development; still others work with the educational partners to develop a detailed competency curriculum as a result observations of students in the workplace and the workplace needs analysis. In most cases, a teacher can and should, however, use the PET as a forum to resolve any conflicting goals for classroom instruction.

The Students The student’s role is to attend all classes and be an active participant with the full support of top management and line supervisors. The student’s feedback is invaluable to the instructor and the PET. Students should assist the instructor in clarifying how the class content and instructional methods will assist him or her in meeting their goals for the class, in their personal lives and for current and/or future job growth. Evaluation activities must include student input. Programs must have an authentic and documented process for assisting students to identify, monitor, and achieve their goals. The goal setting process must be done with a teacher who is likely to have an ongoing relationship with the student. Instruction and curriculum must reflect a balance of students’ personal goals for education with those of the workplace. Goals must inform instruction and be incorporated into a program’s curriculum development process.

Recruitment of Participants Students are at the center of the workplace education program. A successful program recruits employees with both a need and an interest in taking classes. Classes however, must be voluntary; employees must not be required to take any classes. Careful screening and placement assessments in the beginning of each learning cycle will result in a group of students ready to attend and succeed in classes.

The PET should start planning student outreach and recruitment as early as possible. The PET can use WNA interviews, focus groups and contacts to identify possible students, as well as supervisors, workers and union leaders who can help recruit. PET members will need to share ideas and determine recruiting strategies that will work best and most likely involve some PET members in setting up outreach activities. Class enrollment and retention are frequent topics on the PET agenda as work duties and shifts changes are common and the challenge to maintain class enrollment is ongoing. Some successful recruitment suggestions include:

Set up information/sign up tables in highly trafficked areas (break-room, cafeteria) during peak times.

Utilize existing workplace meetings and communication systems (e.g., newsletters, all-staff meetings) to support program outreach.

Translate all written flyers and brochures into languages used by workers in the workplace. Encourage potential students to meet and talk with teacher(s) as often as possible. Attend department meetings to discuss the program with workers in small groups.

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Extend outreach beyond the use of written materials; potential students may be unable to read these materials and never know about the class.

Follow up with workers who signed up for class; make follow up connections before the first day of class.

Describe program in language that promotes new knowledge and skills in a respectful light--does not stigmatize students.

Provide posters, flyers, and announcements around workplace, or show short videos. Offer a demonstration class to attract students.

Program Design Class Design and HoursPartnerships are encouraged to assess the pool of potential students when designing classes. Most partnerships successfully offer one class, but frequently struggle to maintain two or more classes. There is no expectation or requirement on the part of ACLS for a partnership to offer more than one class. The partnership may be able to commit, with confidence, to one class with minimal complexities, e.g., recruiting students from multiple shifts and from multiple departments. Without a significant pool of workers from which to draw, a partnership may be less able to deliver and maintain a second class with good attendance, retention, and other outcomes.

Multi-level classes are almost unavoidable, but there should be a reasonable mix of instructional levels in the class. Partnerships need to design a program where workers can get to class easily and on time, where shifts are stable during the program weeks, and where the goals of the workers in class are similar. Trying to serve the educational goals of workers with radically different needs in one class, e.g., bus drivers and medical assistants is nearly impossible. Partnerships must keep in mind what is manageable to achieve success. Classes must be held at the workplace with only two exceptions. Circumstances under which classes could be held off-site include: 1) a consortium of small companies, where workers travel to one worksite for class; 2) classes offered in a union hall.

Release Time Release time is the paid time the employer agrees is available for the workers to attend class. While release time is not required, it is highly recommended. Some employers offer 100% release time; this level of commitment provides the best incentive for employees to attend classes. In this example, the workers attend class on company time during normal business hours. Other employers are able to offer 50% paid release time for class participation. For example, if a class runs for two hours, the business may cover one hour of pay and the employee is expected to attend for one hour on his or her own time.

If release time is not possible or practical because of heavy workload periods, lean staffing, or complications with scheduling, some businesses offer stipends to employees to attend class, applying the same formula as release time: the employer pays one hour to the employee for attending class and the employee attends class for one hour on his or her own time.

A partnership not able to offer release time must identify strategies to ensure students will attend every class and persist over time. Offering classes during the workers’ lunch time is not a recommended option, although it can be considered in some limited situations.

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Choosing a class meeting time is specific to the realities of the industry and site. Generally, class times are chosen when the most number of people can attend. An example of 50% release time sometimes this happens when one shift ends and another begins. For example, a 2:00 p.m. - 4:00 p.m. class time can work for the 7: 00 a.m. - 3:00 p.m. shift as well as the 3:00 p.m. - 11:00 p.m. shift. Employees from the 7:00 a.m. - 3:00 p.m. shift are released at 2:00 p.m. for class. Employees of the 3:00 p.m.-11:00 p.m. shift arrive to work for class at 2:00 p.m. and start work at 4:00 p.m. In both scenarios, students receive one hour of release time for every 2 hours of class.

Note that long-term classes (not short-term workshops) must be offered so that students improve their academic skills. Each industry has its high and low seasons; each workplace has its own rhythms and staffing concerns. Effective class scheduling takes this into account. If a workplace lays off its staff during slow seasons, it doesn’t make sense to schedule classes during this time. It is unlikely people will return to the workplace just for the classes, and attendance will be severely affected.

Partnerships are required to: offer classroom instruction with a fixed schedule; offer a minimum of 32 instructional weeks; offer the maximum intensity, frequency and duration of instructional services possible; provide a minimum of four hours per week of instruction per class; maintain enrollment of ten students per class.

Calculating the Workplace Coordination Hours Numerous factors determine the number of workplace education coordination hours needed. The size and type of business partner, the number of departments releasing students to classes, as well as the number of partners (labor and management) should be taken into account. In addition, the number and type of classes will need to be considered as well. A partnership, for example, with one business partner offering one class where all students come from one department will need fewer hours of coordination than a partnership with multiple classes and students coming from various departments. A consortium with multiple labor unions and multiple business partners will increase the hours needed for workplace coordination time. The grid below is a guide and suggests ranges of coordination hours based on the number of classes and weeks per year for possible grant awards.

Number & Duration of Classes Range of Coordination Hrs Range of Grant Award1 class - 32-42 weeks per year 15 -25 hours per week $30,000-$45,000

2 classes - 32-42 weeks per year 25-35 hours per week $45,000-$50,000

Paid Class Preparation Time for Teachers (prep)Programs must include paid time for teachers for class preparation. Programs are encouraged to provide the maximum time for teacher preparation: one hour of teaching to one hour of prep time.

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Professional Development for TeachersThe program should make time available for staff to participate in professional development (PD) activities. PD is defined as a structured learning activity designed to strengthen the skills and/or knowledge needed by individual practitioners to perform effectively in their job. Examples of PD activities include peer coaching, study circles, teacher research, mini-courses and institutes, and distance learning opportunities. At the beginning of the year, teachers can reflect on their own strengths and areas for improvement and plan PD accordingly.

Experienced ESOL and ABE teachers with extensive knowledge of teaching approaches can focus on the workplace aspects of the program, becoming more knowledgeable about how the business and unions function, or how other workplace programs have developed contextualized curricula. They can attend conferences and seek out materials that focus on workplace education and workforce training.

Teacher sharing—internally or with other workplace education teachers—can be an invaluable professional development practice. Workplace education teachers are often part-time and off-site from the education providers’ main site; they may have little or no interaction with peers and can feel isolated.

A workplace education coordinator may need support in facilitating the PET meeting using a business-like model, separating information sharing issues from problem solving, and guiding discussions to decision making.

Programs are encouraged to stay up-to-date on emerging research by attending local, regional, and national conferences and by subscribing to relevant journals.

Participation on the PET or curriculum development do not count as professional development activities.

InstructionContextualizing CurriculumContextualized curriculum is the cornerstone of an effective workplace education program. The contextualized curriculum often begins with an explanation of the articulated goals of all stakeholders in the program, supported by the information collected through the WNA, and further clarified through PET discussions.

At many work sites, workers are placed in classes according to their shift schedules with their educational skill level needs a secondary consideration. Multi-level groups also result because workplaces only offer one or two classes into which interested students go. Classes must not be multi-level to the extent that students will not be able to meet their goals and that such classes create heavier preparation loads for teachers.

A curriculum based primarily on thematic units is well suited to workplace education programs. Goals can be chunked into topic areas. For example, beginning level ESOL students often need a unit on identifying themselves, their work, and their work processes. The curriculum can build units that focus on English language, literacy skills and math that integrate speaking, listening, and reading/writing related to these needs. Teachers must base instructional methodologies and strategies on a foundation of research and effective practice. Examples of research-based methodologies include:

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The curriculum incorporates authentic, real-life contexts that are responsive to the needs, goals, and interests of students in their roles as workers, family members, community members, and lifelong learners.

The curriculum is not dependent upon a single publication, workbook, or student text. The curriculum reflects the diverse educational, cultural, and linguistic backgrounds of

the students. A variety of instructional strategies, including whole group, small group, and

individualized instruction, are used to respond to the needs of the student population. Strategies promote student teamwork and leadership skills.

A variety of tools and technologies (e.g., audio-visual, computers, video, and tablets) are used to support learning wherever possible.

Instructional methods include interactive activities to engage a range of learning preferences (e.g., visual, aural, tactile, and kinesthetic).

Teachers create an atmosphere that is conducive to learning and promotes active student participation.

For programs offering ABE instruction, the partnership’s curriculum and its components must be informed by the College and Career Readiness Standards for Adult Education (CCRSAE). The level-specific standards of the CCRSAE provide the skill sets to be mastered, including math and numeracy, ABE thematic curriculum units must be informed by employer needs, the students' goals, needs, and interests and the union (if the workforce is unionized). For a copy of the CCRSAE, see: http://lincs.ed.gov/publications/pdf/CCRStandardsAdultEd.pdf

Partnerships offering ESOL instruction must provide a foundation in English language acquisition so that ESOL students have the language support needed to meet the CCRSAE during instruction. ESOL curriculum and instruction must reflect the CCRSAE instructional shifts and align at all levels with the CCRSAE levels A through D-E. In addition to the CCRSAE, an ESOL curriculum must be supported by the standards and benchmarks of the Massachusetts ABE Curriculum Framework for English for Speakers of Other Languages. The benchmarks in the ESOL Framework provide the skill sets to be mastered in speaking, listening, reading, and writing skills. These benchmarks are also the vehicle by which students develop academic, metalinguistic, and metacognitive skills. For a copy of the ABE Framework for ESOL, see http://ww.doe.mass.edu/acls/frameworks/esol.pdf

Formative Assessment ACLS requires that workplace education teachers integrate formative assessments into their instruction to monitor student progress, inform instruction and provide students with feedback on their progress.

Workplace education curricula are complex; classes are multi-level as the curricula attempts to balance the needs of various workplace stakeholders. Given the highly contextualized nature of the curriculum, teachers need to understand and use a variety of assessment tools to monitor student progress and inform instruction. These tasks can be accomplished by the use of formative assessments. Assessments can determine what is taught, how language and content are taught, how much time teachers spend on a topic, and what activities students are asked to do on a daily basis. Assessment can also better inform teachers on how to group students in the classroom.

Formative Assessment Essentials

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1. Ensure that each lesson has a purpose and that learning targets are connected to the program’s curriculum and thematic units. Assess what is actually being taught. As formative assessments are carried out over time and are not a one-time event, teachers should welcome the opportunity to make the modifications needed as indicated by assessment results.

2. Ensure that teachers check for understanding. Checking for understanding is the link between teaching and learning and should be part of every lesson plan. Ensure there are a variety of ways to carry out these checks. Examples include: observations, listening in as students interact, conferences, exit tickets, and portfolio checks. Teachers may also incorporate questions that require complex and critical thinking, debriefing, student self reports. Student portfolios, student logs, and student journals can be used as part of the assessment process. Many types of assessment can be accomplished easily and quickly as part of a lesson as students can show what they've learned in numerous ways.

3. Ensure that the teacher gives timely and specific feedback to students in language they can understand. Teachers should aim to create an environment where students feel that they are partners in the learning process. Sharing concrete and useful feedback will help to create that collaborative rapport. Be sure that students are aware of the next steps they can take to increase their skills and knowledge.

4. Ensure feedback is followed by a specific plan of action. Now that the teacher is more aware of what students know and don’t know determine what adjustments should be made to the curriculum and instruction.

Outside of the class, there may be opportunities to assess what students can do with their new language and literacy skills. This possibility can be explored with students to check for their comfort level with this or any ideas they may have for out of class practice. Supervisors can be surveyed periodically about students’ progress toward their goals. This works especially well if supervisors have been an active part of the PET, contributing to discussions regarding class content.

Finally, as with all student assessments in the workplace, all individual results must be kept confidential and only reported in the aggregate if used by the PET for larger planning purposes.

Summative AssessmentStates that receive Federal money to support adult education programs are required to report on the educational gain made by students. This data is submitted annually via the National Reporting System (NRS), developed by the Office for Career, Technical, and Adult Education (OCTAE) of the U.S. Department of Education (USED). According to the NRS, the primary purpose of educational gain is to measure improvement in the basic literacy skills of participants in the adult education program. This goal is the reason that all students are counted in the NRS educational gain measure.The NRS approach to measuring educational gain is to define a set of educational functioning levels (EFL) in which students are initially placed when they enter the program based on their abilities to perform literacy-related tasks in content areas. After a set time period or number of instructional hours set by the state, students are again assessed to determine their skill levels. If

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students’ skills have improved sufficiently to be placed in one or more higher levels, a completion2 is recorded. This process occurs every fiscal year, between July 1 and June 30.For more information on the NRS and EFL, see http://www.nrsweb.org/ and http://www.doe.mass.edu/acls/assessment/EFL-FAQ.html.

Assessment PoliciesACLS requires that programs comply with the following statewide assessment policies.

Assessment Policy 1: Three Assessments in a Fiscal YearPrograms may administer no more than three NRS approved assessments per content or skill area in one fiscal year.

EFL progression is based on the first test score (pre-test) and best post-test score achieved in a fiscal year (July 1-June 30).

EFL progression must be achieved within the duration of a fiscal year in order for the EFL outcome to count towards the program’s MSG target. Students must be tested with a NRS approved standardized assessment no more than three times in a content area in a fiscal year. For example, if a student is pre-tested in September and then post-tested in December, EFL progression is determined by the December test score compared to the September pre-test score.

However, if the student is pre-tested in September, post-tested in December and again post-tested in April, the student’s EFL outcome is determined by the higher post-test score compared to the September pre-test score.

Assessment Policy 2: Primary Assessment Area (PAA)A Primary Assessment Area (PAA) needs to be set for students each fiscal year.

A student’s PAA is chosen based on the skill or content area (reading, math, writing, speaking, listening) in which the student needs to improve as expressed by the student or determined by the program. The PAA is set in SMARTT by checking the PAA box for a student’s assessment.

The PAA must be set BEFORE the monthly attendance lockout period.

The PAA must not be changed during the fiscal year except when a student moves from ESOL services to ABE services (or vice versa).

EFL gain outcomes in the PAA and non-PAA count for NRS outcomes. Programs can get 1.0 credit for an Educational Functioning Level (EFL) completion in either a student’s primary assessment area or in the non-primary assessment area. More details on partial credit as part of the MSG standard can be accessed here: http://www.doe.mass.edu/acls/performance/.

Assessment Policy 3: Pre- and Post-TestingPrograms should have systems in place to ensure that students understand why they are pre-tested, what kind of tests will be used as pre- and post- assessments, how many times a year they will be tested and how the score results will be explained to them, and for what purposes the program will use these results.

o Pre-testingThe National Reporting System (NRS) requires that all students who have 12 or more hours of attendance be included in all federal report tables.

2 EFL completion may also be referred to as EFL progression or EFL gain.16

All students must be pre-tested within the first 18 hours of attendance but students can be pre-tested prior to enrollment (with the exception of MAPT, see MAPT section in chapter 5-Test Administration Procedures).

Exception to the 18 attendance hour pre-testing policy

Due to the time-consuming re-testing requirements of the CLAS E-Reading and the CLAS E-Writing assessments (see Chapter 5-Test Administration Procedures below), programs using these two assessments can administer these pre-tests after students have reached 18 attendance hours. It is, however, in the best interest of programs to re-test students (if applicable as per the CLAS E-Writing and CLAS E-Reading re-testing guidelines) as soon as possible to ensure that 65 hours of instruction (see post-testing policy below) occur between pre-tests and post-tests.

All students with a pre-test must be enrolled in the SMARTT database (see assessment policy # 7 below).

o Post-testing Students must have 65 contact hours before they are administered a post-test.

Programs are required to post-test students at least once, but students must not be tested more than three times in a fiscal year in the same content or skill area. Programs have the option of administering a mid-year test if this aligns with the instructional and assessment needs of the student. Programs may not test students with less than 65 hours between their pre- and post-tests with the exception of students enrolled in AECI. These students may be post-tested at 40 hours.

For additional specific MAPT post-testing instructions, see page 25.

*Pre- and Post-Testing of Pre-ASE and Low ASE Students-Effective FY2019Pre-ASE and low ASE- level students must be tested with both Reading and Math.

Students who pre-test at the pre-ASE levels (low intermediate and high intermediate levels, GLE 4-8.9) and at the low ASE level (GLE 9-10.9) must be tested in both Reading and Math including students enrolled in STAR classes at programs offering STAR.

Pre-and Post-Testing of High ASE StudentsStudents placing into the High ASE Level are not required to take a post-test in their PAA or non-PAA.

Because these students’ pre-test score is already high and therefore does not allow them to advance any further, the only educational outcome for students at this level is obtaining their high school equivalency credential. Under the ACLS MSG standard, students have until December 31 following the end of the fiscal year to obtain their HSE credential. Please see more details about the MSG reference period here: http://www.doe.mass.edu/acls/performance/ .

Pre- and Post- Testing of Advanced ESOL StudentsStudents placing at the Advanced ESOL level with a pre-test score below the exit score of 612 for CLAS-E Writing and 588 for CLAS-E Reading but at SPL 6 can still make EFL gain their if post-test score is 612 or above in writing and 588 or above in reading.

Students Enrolled after April 1 Students enrolled after April 1, whether they are post-tested or not, must be included in the MSG denominator and reported to OCTAE. Programs should design services based on student needs and the

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ACLS post-testing policy which applies to all students including those enrolled after April 1 (i.e., 65 hours for CALC students and 40 hours for AECI students).

Assessment Policy 4: Copy-Over of Assessments and the Shelf Life of a Test

*Any assessment administered after April 30 may be copied over into the next fiscal year and used until December 31of that calendar year. Any test administered within a fiscal year (July 1-June 30) may be used as a pre-test for students who leave and return during that year-Effective FY2019.

For example, a student’s test administered on May 2, 2018 (FY 2018) can be copied over and used as a pre-test into the next fiscal year starting July 1, 2018 (FY 2019) until December 31, 2018. If the student leaves before June 30 and returns after December 31, the student must be pre-tested again.

However, for a student who was pre-tested any time during the fiscal year (July 1-June 30), leaves the program and returns within the same fiscal year, administering another pre-test upon the student’s return is not necessary as the student’s previous pre-test may be used again.

Assessment Policy 5: Pre- and Post- Assessment TargetsACLS requires that programs pre- and post-test a minimum of 80% of their students.

Pre- and post- percentage is no longer a performance standard and ACLS no longer assigns points to this target as per the performance standard memo issued on November 2, 2016. ACLS will however continue to track pre/post assessment data through SMARTT and Cognos.

Programs should continue to employ best practices for attendance and retention in order to aim for 100% pre/post testing rate and to ensure that students progress in their academic goals.

Assessment Policy 6: Student Placement

Programs may use any placement tests they choose. Programs may not use the MAPT as a placement test. The TABE 9/10 Locator may be used as a placement test. The BEST Plus 2.0 may be given at intake and may be given as both placement and pre-test. The CLAS-E Writing Assessment and the CLAS-E Reading may be given at intake and may be given as both the placement and pre-test.

Assessment Policy 7: Reporting Assessments in the SMARTT Database

All administered tests must be entered into the SMARTT database whether or not students made EFL gains and no exceptions are allowed. Assessment results must be reported accurately and entered into the SMARTT database before the monthly attendance lockout period.

Assessment Policy 8: Training and Certification of Test Administrators

All test administrators are required to be trained and certified by the SABES Assessment Center before administering any of the standardized assessments used in Massachusetts. ACLS recommends that programs maintain at least two certified test administrators for each test the program administers.

For more information on assessment policy # 8 and standardized assessments used in adult education in MA, see http://www.doe.mass.edu/acls/assessment/.Measurable Skills Gain (MSG) Currently ACLS has created one state performance standard: Measurable Skills Gain (MSG). The state MSG performance standard includes the following outcomes: educational functioning level (EFL) completion, high school equivalency (HSE) credential attainment, and postsecondary

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education and/or training (PSE/T) enrollment after the student exits the program. Annually, programs will be assigned an MSG target using a formula that incorporates (i.e., is weighted on):

a) The number of students who pretest into each of the NRS levels that a program serves, and

b) (Based on historical data) the degree of difficulty in achieving an MSG outcome.

Programs would be ranked based on how close they come to meeting or exceeding their MSG target, and performance will be the actual completion percent relative to the target. (Note: Programs will get one credit (i.e., 1.0) for the first MSG outcome earned; they will get partial credit (i.e., 0.1) for each additional outcome earned beyond the initial MSG. If students in a program achieve an initial outcome and two additional outcomes, then the program’s credit for that student is 1.2.)

MSG outcomes – both initial and additional – can be any of the following: educational functioning level (EFL) completion high school equivalency (HSE) credential attainment postsecondary education or training (PSE/T) enrollment after exit

Here are some examples of how credit is distributed for outcomes: Two EFL completions (i.e., advancement in two NRS levels) by a student = 1.1 EFL completion in two subject areas (e.g., reading, math) = 1.1 High school equivalency (HSE) credential attainment and two EFL completions = 1.2 Two EFL completions in two subject areas plus enrollment in postsecondary education or

training (PSE/T) after exit = 1.4.

MSG Benchmarks and TargetsBecause one of the two factors in an MSG target is the number of students who pre-test into each of the program’s NRS levels, targets could slightly change over the year since pre-testing will continue throughout the year. ACLS will assign programs their ABE and ESOL targets in October of each year. In future years, targets will be listed in the Cognos Summary Report for each program at the “project” level.

Benchmarks Target Percentages

Excellent 135% of Program Target or Higher

Advanced 120 – 134% of Program Target

Above Target 110 – 119% of Program Target

Meets Standard 100 – 109% of Program Target

Needs Improvement 90 – 99% of Program Target

Remedial Action Below 90% of Program Target

For more information on MSG and performance accountability, see http://www.doe.mass.edu/acls/performance/msg.html and http://www.doe.mass.edu/acls/performance.Fiscal and Data AccountabilityOrganizations that accept adult education funds (e.g., a contract, grant funds) also accept fiscal and data accountability. They are held accountable for spending public funds appropriately; maintaining stable financial conditions; operating in a financially sound and transparent manner; and data integrity. Programs that fail to abide by fiscal and data policies will face consequences

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including but not limited to remedial action, withholding of funds, grant reduction, or grant termination.

Record KeepingGrantees and subcontractors must be able to account for the expenditure of all grant funds and demonstrate that required functions are provided according to the approved budget. Fiscal records, Board records, and student records must be kept on file for seven (7) years. Financial and data records must be made available upon request. Falsification of required documentation may trigger a data audit and/or fiscal audit or result in termination of the grant.

Administrative CostsWorkplace education grantees may take up to 20% for administrative costs. The workplace coordination hours are determined differently from the administration hours as outlined in the section entitled: Calculating Workplace Education Coordination hours.

RestrictionsThe following are expenses not allowed to be charged to Workplace Education grants:

high school equivalency assessment fees refreshments membership to adult education advocacy groups such as the Massachusetts Coalition for

Adult Education (MCAE) costs for any education provider staff to travel between the business site and home

Salaries and BenefitsACLS requires that programs compensate staff using the salaries below as a guide. Administrator

- With fringe: $30.00- Without fringe: $39.00

Professional- With fringe: $22.00- Without fringe: $28.00

Support Staff- With fringe: $17.00- Without fringe: $21.00

ACLS requires that programs compensate staff for all job responsibilities including paid prep time for teachers.

Matching FundsThe grant recipient must provide fully auditable matching resources equal to at least 50% of the grant award. The business partner (or business and labor jointly) must provide a 50% match. The education provider is not eligible to provide any part of the match. The business partner demonstrates its commitment to the education program by provision of the match. No cash match is required. The list below, while not all-inclusive, provides some examples of eligible match. No grant funds may be used to compensate any employee of the business partner.

Release time for employees to attend class Time business partner representatives participate in PET (hourly rate X # hours) meetings Time labor union representatives participate in PET (hourly rate X # hours) meetings Educational and office supplies for the program Purchase of or use of existing equipment e.g., computers, white boards

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Advertising for recruitment purposes Meeting space for the PET with formula Classroom space for instruction with formula

Note: When space is claimed as match, the formula is the cost per sq. ft. used by the program (e.g., classrooms, office space) multiplied by the percentage of time the space is used by the program.All requirements that apply to ESE grant funds also apply to matching funds.

Staff salaries of the education provider

No Charges to StudentsStudents should receive instructional materials at no cost.

Materials and Supplies including Computing Devices3

Costs for materials and supplies necessary to carry out a Federal award are allowable. Materials and supplies4 refer to all tangible property other than that described in the Equipment section below. Purchased materials and supplies must be charged at their actual prices.Grantees must maintain effective control and safeguard all assets and assure that they are used solely for authorized purposes regardless of cost.

Control of Computing Devices and EquipmentProperty records for computing devices and equipment must be maintained. Records must include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date and cost of the property, percentage of Federal participation in the costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and, if applicable, sale price.

Disposal of Computing Devices and Equipment5

Programs that have usable equipment and/or computing devices purchased with grant funding, which will no longer be used on behalf of an ESE-funded program, should notify their ACLS program specialist so the program specialist can facilitate the reallocation of the usable equipment and/or computing devices to programs in the region. (Note: Date of disposal and sale price, including the method used to determine fair market value, if applicable, must be added to the equipment inventory.)Code of Federal RegulationsThe Code of Federal Regulations (CFR) is the codification of the rules published in the Federal Register by the Federal government. The regulations summarized below, specifically Title 2 of the CFR Grants and Amendments, Subparts A through E, are a point of reference but do not encompass the full extent of grantee responsibilities. Grantees should familiarize themselves with 2 CFR 200. For more information on the CFR, see https://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl.3 See 2 CFR §200.302(b)(4), §200.314 and §200.453.4 Supplies include computing devices if the acquisition cost is less than $5,000, regardless of the length of their useful life. Computing devices means machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories or peripherals for printing, transmitting and receiving, or storing electronic information.5 See 2 CFR §200.313.

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Statement of Assurances (SOA)Each year an authorized signatory of the program must submit a signed SOA which assures compliance to ESE policies. The failure of a program to demonstrate compliance with the policy requirements in the Massachusetts Policies for Effective Workplace Education Partnerships and in subsequent policy updates throughout the year will have consequences, including but not limited to remedial action, withholding of funds, grant reduction, or grant termination.

Risk Management6

ACLS has a risk management process in place to ensure that grants are used appropriately and in compliance with their awards and all associated policies and regulations. ACLS will continually assess program risk using a risk assessment rubric designed to identify fiscal and programmatic conditions that could put Federal and state funds at risk. Depending upon the assessment, mitigation could involve training and technical assistance, additional site reviews including fiscal and data audits, stops on grant payments, and grant reduction or termination.

Financial Audit RequirementAll grantees are required to annually submit an electronic copy of the organization’s latest audit report issued by an independent CPA to the ESE Audit and Compliance unit. These include a copy of the audited basic financial statements and a Management Letter or, for entities that expend $750,0007 or more in Federal funding, a Single Audit. Audits must be submitted 30 days after receipt of the auditor's report(s), or nine (9) months after the end of the fiscal year—whichever comes first.

Fiscal ResponsibilitiesGrantees must ensure that grants are managed with sound stable fiscal systems and a comprehensive system of internal policies and procedures (i.e., controls) that meet applicable state and Federal requirements. This policy also applies to subcontractors.

Indirect Costs8

Indirect costs (IDC) are costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted. Grantees that receive IDC should have a cost allocation plan that tracks those costs for audit purposes.Grantees that have a federally approved IDC rate can apply to ESE for up to an 8% IDC rate and include documentation of the federally approved rate. Grantees that do not have a federally approved rate can apply to ESE for up to a 5% IDC rate. If a grantee receives IDC and funding from another line (i.e., other costs), these costs must not overlap.Grantees that plan to charge indirect costs (IDC) must annually apply to ESE for an approved IDC rate prior to submission of grant applications. Grantees that do not have an approved IDC rate will not be able to claim indirect. For more information on IDC, see http://www.doe.mass.edu/grants/procedure/default.html.When the direct grantee and a subcontractor both have approved ESE IDC rates, both agencies may charge indirect costs to the grant. However, the total dollar amount charged for indirect costs must not exceed the maximum IDC dollar amount for which the direct grantee is eligible.When the direct grantee has an approved indirect cost rate but the subcontractor does not, the subcontractor may charge the same indirect cost rate as long as the dollar amount of the total 6 See 2 CFR §200.205.7 See 2 CFR §200.501.8 See 2 CRF §200.56.

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indirect charged to the grant does not exceed the maximum dollar amount for which the direct grantee is eligible.When a subcontractor has an approved indirect cost rate but the direct grantee does not, the subcontractor cannot claim indirect costs. Subcontractors are bound by the maximum amount the direct grantee can charge under the grantee’s approved indirect rate.

Time and Effort Reporting9

Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated. Payroll distribution records must be incorporated into the official records and reasonably reflect the employees’ total activity. Additionally, records need to support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Time and effort reporting documentation requirements also apply to salaries counted as match under the grant. A reasonable method of tracking time and effort must be employed. Estimates may be used, however, reconciliation to actual time worked and charged (i.e., planned vs. actual) must occur on a regular basis. Time worked, level of effort, and dollars charged are not independent of each other; they are linked and methodologies for tracking, reporting, and the internal controls that are in place need to be part of the documentation associated with personnel charges to ESE grants.

General AdministrationGrant funds may not be used to pay for expenses that have been paid for by other local, state, Federal, or private awards. Programs must have effective accounting systems in place to track expenditures including responsibility for monitoring subcontracts and ensuring that all grant funds are expended as articulated in the Memorandum of Agreement (MOA) between partners. Grantees must maintain separate and auditable records for each project for which the grantee receives funds; time and attendance records must support payrolls; and time distribution records must support salaries and wages of employees chargeable to more than one grant program. Grantees must develop and submit an annual budget that supports the services approved in the grant. Grant budgets must be submitted by authorized personnel by the deadlines specified in the EDGrants system. For more information on grant management and EDGrants, see http://www.doe.mass.edu/grants/procedure/manual.html and http://www.doe.mass.edu/news/news.aspx?id=21776 respectively.

Requests for FundsGrantees must monitor monthly expenditures carefully and draw down funds as needed to ensure that state funds are expended regularly and in full by the close of each fiscal year. This process is done online.

AmendmentsGrant amendments are required when there is:

a significant change in program objectives; an increase or decrease in the total amount of the grant; or an increase in a line item that exceeds $100 or 10% of the line, whichever is greater, or

exceeds $10,000.When an amendment is required, the program must consult with its assigned ACLS program specialist for approval of the proposed changed prior to submitting an amendment electronically

9 See 2 CFR §200.430.23

via the EdGrants system. In order to allow time for amendments to be processed, programs must submit amendments at least 30 days prior to the desired change and/or 30 days before the end of the fiscal year.

Unexpended FundsGrantees must monitor expenses on state grants to ensure that funds are used within the fiscal year. State regulations provide no flexibility for the use of state funds after June 30. Unexpended funds above $1.00 must be returned with the final financial report (i.e., FR-1) each year.Grantees must notify ACLS as soon as possible if funds may be unspent including funds assigned to subcontractors so that grant funds can be reallocated. Grantees that return funds above 1% of the grant amount more than once within a funding cycle may trigger a fiscal audit. Grantees that inform ACLS in a timely manner regarding funds that need to be returned and submit an amendment will be held harmless. Grantees that repeatedly return funds, including less than 1%, may get their subsequent award reduced by the amount of the funds returned and may not be eligible for increases offered during the following year. For ACLS Contact Information, see Appendix E.

Condition of FundingAs a condition of accepting ESE funding, grantees commit to identifying ESE as the entity supporting the delivery of adult education services at the program in any official correspondence. Additionally, grantees agree that ESE will have the right to publish and distribute any materials developed with grant funds.

Record KeepingGrantees and subcontractors must be able to account for the expenditure of all grant funds and demonstrate that required functions are provided according to the approved budget. Fiscal records, Board records, and student records must be kept on file for seven (7) years. Financial and data records must be made available upon request. Falsification of required documentation may trigger a data audit and/or fiscal audit or result in termination of the grant.

Data Quality and IntegrityAttendance For reporting purposes, ACLS counts the following as attendance:

the time that a student is physically present in class on the date and at the time of scheduled classes (i.e., classroom attendance);

one on one volunteer tutoring time outside of scheduled classes; distance learning attendance as proxy seat time (i.e., clock time model, learner mastery

model); and blended learning (also known as hybrid learning) attendance as a combination of

classroom attendance and proxy seat time.For more information on distance and blended learning, see http://www.doe.mass.edu/acls/dl/.

SMARTT Data Entry

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Data entry, including student attendance, assessment, PD participation, and other information as the need arises must be entered accurately and in a timely manner according to a fixed, regular schedule. Data entry must be consistent with program records in the grantee’s files.

Data Lock-out and Data Lock-out SchedulePrograms will ensure that data entry in SMARTT is entered in a timely manner according to a fixed, regular schedule. Programs are advised that they will not be able to enter enrollment and attendance data once it has been “locked-out.” Data for each month must be entered by the last day of the following month as indicated in the following schedule, with the exception of July and September in which two months are given for data entry.

If a program misses a data lock-out, it can send an email to the ACLS Administrator (copying the ACLS program specialist) requesting permission to enter data after the lock-out and providing strong reasons for the request. Requests will be considered on a case by case basis. Repeated requests may trigger a data and/or fiscal audit.

Month of Attendance Locked-Out DateJuly September 30August September 30September November 30October November 30November December 31December January 31January February 28 or 29February March 31March April 30April May 31May June 30June July 31

Follow-up for Federal WIOA MeasuresThe NRS requires states to track WIOA-required outcomes (e.g., employment, obtaining a high school equivalency credential, entry into postsecondary education or training). Students who have not participated for 90 days are officially exited from the program and become part of a follow-up cohort. Programs must conduct post-exit follow-up for students in these cohorts even for students who return to the program later in the year. For more information on the NRS, see http://www.nrsweb.org/.

Follow-up and Automatic Exit ScheduleIt is in the best interest of programs to capture NRS-required outcome data for students in the follow-up cohort. This can be accomplished either by survey or data matching. However, a survey must be used for students who either did not provide a social security number (SSN), or did not sign a release of information (ROI) form for employment follow-up and/or entry into postsecondary education/training. To ensure accurate reporting, SMARTT will automatically

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exit a student from the program if no attendance has been recorded during the three-month period immediately following the last month of attendance as indicated by the following schedule.

Automatic Exit Schedule

Month of Last Attendance

No Attendance in these Months

System Assigned Exit Date

July 15 February March—May February 28 or 29

August 15 March April—June March 31

October 15April May—July April 30

May June—August May 31

November 15 June July—September June 30

December 15 July August—October July 31

January 15 August September—November August 31

February 15 September October—December September 30

March 15 October November—January October 31

April 15 November December—February November 30

May 15 December January—March December 31

June 15 January February—April January 31

For more information on performance standards, EFL, and the NRS, see http://www.doe.mass.edu/acls/performance, http://www.doe.mass.edu/acls/assessment/EFL-FAQ.html, and http://www.nrsweb.org respectively.

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APPENDIX A Alignment with Local Plan Packages

Dear Director:In keeping with the goals of WIOA, the proposed workplace education services must be aligned with the local plan package for the workforce development area in which the services are to take place. Please convene a subcommittee to review the attached proposals for alignment with the local plan package and return this form completed for each proposal to: _____________ by ________________.

The Workforce Development Board (WDB) director will convene a subcommittee to review the proposal for alignment with local and regional priorities and submit this form to ESE/ACLS to inform the proposal review process.

Template

Please Insert Letterhead of the local Workforce Development Board

This is to acknowledge our review of the workplace education proposal ______________________________________________________________________________. (insert name of education provider) and (insert name of business partner), (If applicable, insert name of Labor Union partner)

Based on the review of the proposal for the alignment with the local plan package the WDB subcommittee determined that:

Please check one.

The reviewed proposal aligns with the local plan package and priorities for this local workforce area. We support the type of [Describe service type, e.g., ESOL, ABE, Math, etc.] proposed by this provider.

Comments that support local plan package alignment (optional):

________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

The reviewed proposal does not align with the local plan package and priorities for this local workforce area.

Comments that support lack of local plan package alignment and recommendations for alignment:________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

(WDB Director) (date)