Summary of 60-day FRN public comments and responses

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Overview

Survey
Answers

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Sheet 1: Survey

	U.S. Department of Labor			OMB No. 1205-XXXX
	Employment and Training Administration			Expires: XX/XX/XXXX
	Office of Trade Adjustment Assistance
	The purpose of this collection is to collect data on state organization and operations to facilitate the identification of best practices in the TAA program. Unless otherwise specified, responses should be limited to staff, benefits, and processes used in the TAA program. However, the TAA program should include all TAA-funded staff, benefits, and processes including, but not limited to, Trade Readjustment Allowances (TRA) and Reemployment Trade Adjustment Assistance (RTAA).
	Paperwork Reducation Act Statement
	According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless such collection displays a valid OMB control number. Public reporting burden for this collection of information is estimated to average 5 hours per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. The obligation to respond to this collection is mandatory under Section 239(c) of Title II, Chapter 2 of the Trade Act of 1974, as amended (19 USC § 2271 et seq.). Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the U.S. Department of Labor, 200 Constitution Avenue, N-5428, Washington, D.C. 20210, and reference the OMB Control Number. Note: Please do not return the completed TAA State Survey to this address.
	Confidentiality Statement
	The U.S. Department of Labor will protect the confidentiality of the information you provide to the full extent of the law, in accordance with the Trade Act, 19 USC § 2272 (e)(3)(c), the Trade Secrets Act, 18 USC § 1905, the Freedom of Information Act, 5 USC § 552, and 29 CFR Parts 70 and 90.
	Definitions
	FTE - Full-Time Equivalent workers. Staff who work less than full time or split their time between the TAA program and other programs should be recorded by the portion of time they spend on the TAA program. For example, a staff member who is full time but only spends half their time on TAA should be recorded as 0.5 FTE.
	Local Office - A comprehensive or affiliate one-stop center.
	Region - A sub-state group of local offices or geographic area for administrative purposes for the TAA program. This may or may not be the same as regional designations under other programs.
	COTS - Commercial Off The Shelf System
	Fiscal - This is the state unit or office that generates fiscal reporting such providing information to be entered on the ETA-9130 form.
	#	Questions		Response
State Organization	1	How many TAA Merit Staff do you employ? (FTE - see definition above) (FTE for all merit staff supporting the TAA program including state, local, case managers, reporting, fiscal, and other staff.)				From Margaret Vanwagner (Iowa): Does this include finance staff? Does this include reporting staff? Are you including local office staff or just state office staff? OTAA RESPONSE: This one is intended to be total including finance staff if they are TAA Merit staff. Will clarify the question by saying Merit staff supporting TAA. From Kathy Nesmith (Idaho): What is the intent of Question #1 compared to Q #3? Are they asking for Program vs Admin staff? The questions seem the same. OTAA RESPONSE: Q1 is intended to get a total while Q3 is just looking at state-level staff. Adding clarifying statements to these staff counts.
	2	How many FTE are employed at the state-level? (FTE for all merit and non-Merit staff supporting the TAA program at the state level including program, reporting, fiscal, and other staff.)				From Margaret Vanwagner (Iowa): All state level FTEs (agency-wide) or only TAA? If only TAA, does this include finance staff? OTAA RESPONSE: This is specific to TAA staff, but does include reporting, fiscal, and other staff. Will add a clarifying statement.
	3	How many state-level FTE do you employ for the purpose of providing support to local offices on TAA-related issues? (Estimates allowed. Includes merit and non-merit staff, staff grouped into "regions" to support local offices, as well as staff in other units supporting TAA such as Rapid Response. Excludes local staff such as TAA case managers. Excludes state staff who do not directly support local offices such as reporting staff and finance staff.)				From Margaret Vanwagner (Iowa): Does this include finance staff? OTAA RESPONSE: Adding a clarifying statement that fiscal staff are excluded, but they generally would not support local offices on TAA-related issues.
	4	How many FTEs are employed by local offices (includes case managers)? (Estimates allowed. Includes merit and non-merit staff and case managers directly supporting TAA participants).				From Margaret Vanwagner (Iowa): Does this include all staff or TAA related staff only? Does this include only state merit staff, or non-merit staff as well? Comment: Capturing non-merit staff supporting TAA participants may provide a more accurate picture of FTEs supporting the program. OTAA RESPONSE: All staff supporting TAA and both merit and non-merit staff. Adding clarifying language. From Joan Kilian-Ikeler and Sarah Simonson (Wisconsin): allow for estimation/range for shared program staff - specify if it should include management too. OTAA RESPONSE: Good suggestion. Allowing for estimates here.
	5	How many local offices does your state have?
	6	Regions group local offices for the purposes of support or administration and generally have staff specific to support that group of local offices. Are your local offices set up into regions?				From Joan Kilian-Ikeler and Sarah Simonson (Wisconsin): how should we differentiate between a region and a local office? Workforce development areas? OTAA RESPONSE: Yes. This is specific to regions that group local offices. Adding clarifying language.
	7	If so, how many regions does your state have?
	8	How many total FTEs are associated with regions in the state?
	9.1	Rank which group is most likely to file a TAA petition (1= most common and 5 is the least common. Leave blank if not used)?	TAA State Staff			From Kathy Nesmith (Idaho): 2. Only under the “State Organization” section is there options for group most likely to file a TAA petition. Are “companies” and “unions” considered in the overall data collection? OTAA RESPONSE: This collection is specific to how states administer the program and what bodies within the state are filing petitions. OTAA collects data on whether petitions are filed by workers, unions, companies, or a state/local agency outside of this collection.
	9.2		TAA Local Staff
	9.3		Rapid Response State Staff
	9.4		Rapid Response Local Staff
	9.5		Other Local Staff
	10.1	Estimate the distribution of experience for TAA staff involved in state administration of TAA (percentage of staff):	% Expert
	10.2		% Intermediate
	10.3		% Novice
	11.1	Estimate the distribution of experience for local staff involved in TAA case management (percentage of staff):	% Expert			From Myra Huhmann (Missouri): 2) In my opinion, it will be very difficult for states to gauge the experience of local staff involved in TAA case management. With the TAA program, there is a high turnover ratio and those deemed to be intermediate to expert TAA case managers may not always have high TAA activity in their areas. If you have knowledge and you don’t apply it, you may lose the knowledge over time. OTAA RESPONSE: Noted. Estimates are allowed in the distribution. It is not assumed that local staff will only increase their expertise over time.
	11.2		% Intermediate
	11.3		% Novice
	12	Is new client intake conducted by state merit staff or non-merit staff?What is the State Merit Status of Staff Conducting New Client Intake?				From Joan Kilian-Ikeler and Sarah Simonson (Wisconsin): is this asking whether merit staff conduct new client intake? OTAA RESPONSE: Yes. Rewording to ask it more clearly.
	13	Are the case managers most closely working with TAA participants state merit staff or non-merit staff?What is the State Merit Status of Case Managers?				From Joan Kilian-Ikeler and Sarah Simonson (Wisconsin): is this asking whether case managers are merit staff? OTAA RESPONSE: Yes. Rewording to ask it more clearly.
	14	Would you categorize your state as centralized or localized? This is a broad generalization based on the balance of centralized decision-making and coordination vs. localized autonomy. The answer may consider, but is not limited to, whether state or local staff determine procedures for approving TAA benefits, whether forms are standardized across the state or locally created, who creates policies such as co-enrollment policy, and whether IT systems are integrated or decentralized.				From Joan Kilian-Ikeler and Sarah Simonson (Wisconsin): additional definitions/descriptions would be helpful OTAA RESPONSE: Adding clarifying language.
Determinations for Eligibility and Participant Training	15	Does your State use UI wage records to determine TAA eligibility?
	16	Does your State use Federal Employer Identification Numbers (FEIN) in whole or in part to determine TAA eligibility?
	17	What Unit Contacts Employers to get the Worker List?
	18	What Unit Determines initial TAA Eligibility (in the certified workergroup, not for individual benefits)?
	19	Which Staff Determine initial TAA Eligibility (in the certified workergroup, not for individual benefits)?
	20	Which Staff make TAA Training Eligibility Determinations?
	21	Which Staff make TRA Eligibility Determinations?				From Myra Huhmann (Missouri): 1) The “purpose” of the TAA State Survey references Trade Readjustment Allowance (TRA) and Reemployment Trade Adjustment Assistance (RTAA). In my state, for instance, TAA functions and TRA/RTAA functions are handled by two separation agencies. There are multiple questions that ask which unit or what staff make determinations on a variety of functions, but it may need to clarify first, which Department/Division before determining which unit, etc. OTAA RESPONSE: This is definitely something we want to collect, but that is covered in the integration section when we ask if TAA and TRA are part of the same unit. However, we will add a question on whether they are part of the same department.
	22	Which Staff make A/RTAA Eligibility Determinations?
	23	Is there a training amount threshold over which additional approvals must be obtained?
	24	If so, what is that amount?
	25	Does the state approve stand-alone remedial training without the goal of subsequent credential attainment?
	26	Does the state require training plans to include credential attainment?
Integration	27	Rate the level of integration between TAA and Rapid Response (1 is low, 5 is high):
	28.1	TAA and Rapid Reponse Coordination is done through (select all that apply):	Same Department
	28.2		Same Unit
	28.3		Same Administrator or Manager
	28.4		Shared Meetings
	28.5		Shared Trainings
	28.6		Cross Attendance of Unit Meetings
	28.7		Systematized Process (Electronic)
	28.8		Email
	28.9		Other Formal Process
	28.10		Informal
	29	Rate the level of integration between TAA and TRA (1 is low, 5 is high):
	30.1	TAA and TRA Coordination is done through (check all that apply):	Same Department
	30.2		Same Unit
	30.3		Same Administrator or Manager
	30.4		Shared Meetings
	30.5		Shared Trainings
	30.6		Cross Attendance of Unit Meetings
	30.7		Systematized Process (Electronic)
	30.8		Email
	30.9		Other Formal Process
	30.10		Informal
	31	Rate the level of integration between TAA and Fiscal (1 is low, 5 is high):
	32.1	TAA and Fiscal Coordination is done through (check all that apply):	Same Department
	32.2		Same Unit
	32.3		Same Administrator or Manager
	32.4		Shared Meetings
	32.5		Shared Trainings
	32.6		Cross Attendance of Unit Meetings
	32.7		Systematized Process (Electronic)
	32.8		Email
	32.9		Other Formal Process
	32.10		Informal
	33	Rate the level of integration between TAA and WIOA Title 1 (1 is low, 5 is high):				From Joan Kilian-Ikeler and Sarah Simonson (Wisconsin): should these specify local staff instead of state-level? OTAA RESPONSE: Breaking out questions to be granular about where the integration would be overly burdensome on states. If only local or only state staff are integrated it would probably receive a middle value for level of integration as it is only partially integrated.
	34	Rate the level of integration between TAA and Business Services (1 is low, 5 is high):
	35	Rate the level of integration between TAA Remedial Training and the Adult Basic Education program (1 is low, 5 is high):
	36	Rate the level of integration between TAA and Adult Education (1 is low, 5 is high):
	37	Rate the level of integration between TAA and Apprenticeship (1 is low, 5 is high):
	38	Rate the level of integration between TAA and JVSG (1 is low, 5 is high):
	39	Rate the level of integration between TAA and Vocational Rehab (1 is low, 5 is high):				Hoekstra, Robert - ETA: Internal discussion of collecting information on Common Exit Policy and potentially co-enrollment. Does your state currently utilize a common exit policy? 1. No 2. Yes, including TAA, Title I, and Title III. 3. Yes, including TAA and Title I but not Title III. 4. Yes, including TAA and Title III but not Title I. 5. Yes, but TAA is not included.
	40	Does your state currently utilize a common exit policy?
	41	What is your state co-enrollment policy for TAA participants and WIOA Adult?
	42	What is your state co-enrollment policy for TAA participants and WIOA Dislocated Worker?
IT Systems and Reporting	43	Does your state have a performance reporting or data analysis unit that incorporates TAA?
	44	How many FTE work on performance reporting or data analysis (including contract staff)?
	45	Are there designated staff specializing in TAA data?
	46.1	That unit provides data and analysis to: (check all that apply)	DOL
	46.2		State Stakeholders
	46.3		Local Stakeholders
	47	How many different IT systems are used in the generation of the TAA PIRL?
	48	What type of system is your current case management system?				From Joan Kilian-Ikeler and Sarah Simonson (Wisconsin): more info needed: do you want functionality, info gathered, or do you want just the name? OTAA RESPONSE: The field drop down provides the options, but added the clarifying language "type of system"
	49	What is your primary case management vendor (if any)?
	50	Has your state used TAA case management funds for IT upgrades in the last 3 years?
	51	Date of last major IT upgrade to TAA Case Management System(s) completed?
	52	Estimated completion date of next expected major IT upgrade to TAA Case Management System(s), if known?
	53	Date of last major IT upgrade to UI System(s) completed?				From Kathy Nesmith (Idaho): What is the purpose/relevance of questions 50 and 51 - UI IT upgrades to the system? OTAA RESPONSE: As far as 50 and 51, these give us an idea on state workload (going through IT upgrades), how up to date they are with regard to new requirements, if the system was designed around previous program iterations that operated differently, etc. Mostly though, it will help us try to figure out if there is an optimal frequency with which to do upgrades. I would expect that both very out of date systems are no great, and ones that are constantly undergoing changes results in data issues
	54	Estimated completion date of next expected major IT upgrade to UI System(s), if known?
	55	Date of last major IT upgrade to Financial System(s) completed?
	56	Estimated completion date of next expected major IT upgrade to Financial System(s), if known?
	57	What best describes the current use of electronic files by your Case Managers?				From Joan Kilian-Ikeler and Sarah Simonson (Wisconsin): more info needed: best describes it how? OTAA RESPONSE: Options are in the drop down, but re-worded to make the question clearer.
	58	Does your state have an online portal for participants?
	59	Can users search for jobs on that system?
	60	Are users directed to case manager contact information in that system?
	61	Can users communiate with case managers through that system?
	62	Can users do real-time communication with case managers through that system?
	63	Can users get information on the TAA program on that system?
	64	Can users get information on their individual TAA eligibility in that system?
	65	Can users get information on their individual TAA benefits in that system?
	66	Can users complete required forms for receiving TAA benefits and services through that system? (1 = No, 5 = All TAA Forms) If no, skip to question 75.
	67	Can an application for TAA be completed?
	68	Can an application for Training be completed?
	69	Can an application for TRA be completed?
	70	Can an application for A/RTAA be completed?
	71	Can an application for Job Search Allowance be completed?
	72	Can an application for Relocation Allowance be completed?
	73	Are there other forms that can be completed online?
	74.1	How are signatures addressed? (select all that apply)	Electronic Signature or Certification
	74.2		Upload Scanned Signed Documents
	74.3		Signatures in Person
Training for TAA Staff	75.1	How is training delivered to state and local staff? (check all that apply)	Handbook
	75.2		Conferences (Select Frequency)
	75.3		Webinars (Select Frequency of New Webinars Created)
	75.4		Regular Conference Calls (Select Frequency)
	75.5		Online Forums or Similar
	75.6		Document Depot
	75.7		New Employee Orientation
	75.8		Other
Outreach	76	Are public information materials for TAA developed by your state?
	77	If so, what unit develops those materials?
	78	In your State, what portion of potentially TAA eligible worker groups have petitions filed?
	79	Do you have a process for evaluating WARN Notices to determine if a petition should be filed?
	80	Do you have a process for evaluating layoffs not requiring a WARN Notice to determine if a petition should be filed?
	81	Total number of workers notified of group eligibility to apply for TAA in the last year? (estimates allowed)
	82	What percentage of TAA certified workers acknowledged the notification? (estimates allowed) Acknowledgement is any action the worker takes that indicates the notification was received. This may be a returned email, a returned call, a system access, or anything similar.
	83	What percentage of TAA certified workers apply for TAA benefits or services? (estimates allowed)
	84.1	What methods are used to contact workers? (for all that apply, please rank based on how frequently they are used with 1 being most frequently used)	Employer/Union/Peer Counselor as Intermediary
	84.2		Emails
	84.3		Phone Calls
	84.4		Newspaper Notices
	84.5		Online Notices
	84.6		Social Media
	84.7		Text Message
	84.8		Mailed Letters
	84.9		Other Method
	85.1	What sources are used for identifying worker contact information? (for all that apply, please rank based on how frequently they are used with 1 being most frequently used)	Employers
	85.2		Union Officials
	85.3		State Records (UI, Coenrollment, etc.)
	85.4		Other Workers
	85.5		Worker Self-Identification
	85.6		Rapid Response Surveys / Sign-Up Sheets
	85.7		Other Sources
JSR	86.1	When are job search and relocation allowances offered? (select all that apply)	During Initial Discussion of Potential TAA Benefits			From Myra Huhmann (Missouri): 3) Regarding the question, “When are job search and relocation allowances offered?”, in my opinion, there should be another answer available that indicates during the initial review of benefits and services. OTAA RESPONSE: Added.
	86.2		At Case Manager Discretion
	86.3		At Training Completion
	86.4		At a Required Specific Follow-Up Time
	86.5		When Informed About Job Search/Placement Progress
Barriers	87.1	Rank the following challenges to TAA program operation (for all that apply, please rank with 1=Most Significant Barrier)	Companies Not Informed About TAA Program
	87.2		Identifying Potentially TAA Eligible Layoffs
	87.3		Difficulties Filing TAA Petitions
	87.4		TAA Petition Processing Time
	87.5		Difficulties Determining Individual Program Eligibility
	87.6		Difficulties Determining Individual Benefit Eligibility
	87.7		Difficulties Understanding TAA Guidance/Regulations/Law
	87.8		Reaching Affected Workers
	87.9		Workers Not Informed About TAA Program
	87.10		Worker Disinterest in Program
	87.11		Worker Unwillingness to Complete Paperwork
	87.12		Language Barriers
	87.13		Difficulties Obtaining Information from Other State Agencies
	87.14		Staffing
	87.15		Funding
		Comments (Optional)
	88
		Affirmation of Information
		Knowingly falsifying any information on this form is a Federal offense (18 USC § 1001) and a violation of the Trade Act (19 USC § 2316). By signing below, you agree to the following statement: “Under penalty of law, I declare that to the best of my knowledge and belief the information I have provided is true, correct, and complete.”
		Name	Title
		Email	State Workforce Agency
		Signature	Date

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Sheet 2: Answers

40	41-42	57	75
No	No Co-Enrollment	Operate Exclusively in Paper	Yes - More than 30 per year
Yes, including TAA, Title I, and Title III.	Case Manager Discretion	Work Primarily in Paper	Yes - 21 to 30 per year
Yes, including TAA and Title I but not Title III.	Referral Required	Maintain both an Electronic and a Paper Case File	Yes - 11 to 20 per year
Yes, including TAA and Title III but not Title I.	Co-Enrollment Required	Work Primarily Electronically with Some Processes Still Paper	Yes - 3 to 10 per year
Yes, but TAA is not included.	Varies by Local Area	Work Electronically with All Paper Documents Uploaded to the Electronic System	Yes - 1 to 2 per year
		Work Electronically with All Documents in Electronic Format	Yes - Less than Annually
			No