American Association of Community Colleges Association of Community College Trustees

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1 American Association of Community Colleges Association of Community College Trustees AACC and ACCT Policy Recommendations for Reauthorization of the Carl D. Perkins Career and Technical Education Act The Carl D. Perkins Career and Technical Education Act remains a vital element of support for community colleges in their mission to educate our increasingly technical workforce. The Perkins Act is the largest federal discretionary funding source of direct, institutional support for community colleges. Thus, community colleges are keenly interested in the next reauthorization of the Act (Perkins V). The following recommendations are based on numerous discussions, surveys and other methods of feedback from our member institutions. AACC and ACCT look forward to working with Congress towards a bipartisan Perkins Act reauthorization. Focus on Quality CTE: Community colleges support further refinement of the Perkins statute to ensure that the funding it provides is focused on high-quality CTE programs that prepare students to be college and career ready. Perkins IV made great strides to move the understanding and reality of CTE away from the outmoded concept of programs leading to dead-end jobs (or no jobs), and Perkins V should build on those accomplishments. Community colleges have long believed that secondary CTE programs must prepare students for postsecondary education. In fact, by 2020 it is estimated that 65 percent of all jobs will require postsecondary education and training beyond high school. We believe that Perkins V should reflect the economic demand for postsecondary education and training, and create strong pathways for students of all types to attain fundamental educational skills, as well as a postsecondary degree or industry recognized credential. AACC and ACCT support the efforts of the Career Readiness Partner Council that seek to define the skills and knowledge necessary for career readiness. AACC participated in this undertaking led by the National Association of State Directors of Career and Technical Education Consortium to further examine the practical definition of universal college and career readiness standards. We support incorporating the ideas presented by the Career Readiness Partner Council into Perkins V. All students should receive the academic and technical skills, as well as employability knowledge to support shortand long-term career goals. In addition, we support stronger emphasis on tools such as dual enrollment, work experiences, integrated delivery of basic skills and CTE instruction, and stackable postsecondary credentials. Since the enactment of Perkins IV, there has been significant development in many of these areas, and the reauthorized statute should ensure that they are well represented in required and permissible uses of funds. Counseling is also important. Several states have implemented, or are considering, initiatives that place college-employed counselors in local high schools to supplement the efforts of their guidance counselors, to ensure that students are aware of the various postsecondary options available to them, and the steps they need to take in high school to avail themselves of them. A crucial aspect of establishing a highly-effective CTE program, particularly at the postsecondary level, is that it prepares students for available, quality jobs in their local areas. Perkins V should include provisions that ensure that states and local entities are using the tools available to them,

2 including direct consultation with industry and labor market information, to ensure that this is the case. These efforts should include state-identified industries, as well as substantive input from local and regional areas regarding industry need. The flexibility to incorporate local and regional labor market information is important everywhere, but especially so in large states where local economies can vary greatly. Increase Investment While Maintaining the Current Funding Focus: At the postsecondary level, funding should continue to focus on the sub-baccalaureate level, because that is where the greatest job growth is occurring and where resources are needed the most. Postsecondary eligibility requirements should continue to include only public and private, nonprofit institutions. We remain supportive, however, of the provisions incorporated in Perkins IV that allow funds to be used for easing the transition of students from sub-baccalaureate to baccalaureate institutions. Perkins CTE funds are even more important in this era of decreased public support for higher education. Additionally, Perkins funds themselves have been reduced in recent years, including the elimination of Tech Prep. Further cuts to the program - including redirecting significant funding into competitive grants could greatly impact students. Community colleges urge Congress to produce final Perkins legislation that allows for increased investment in quality CTE, which is crucial to the 21 st century economy. Accountability: Community colleges are strongly in favor of establishing consistent definitions and metrics to enable a clearer picture of the performance of career and technical education at the national and state levels. This starts with more clearly defining the population of students upon which the indicators are based. These students should be those that, through their academic behavior, have shown an intent to pursue a credential in a CTE program. Accountability measures should be streamlined to focus on the key outcomes of completion, retention and employment that form the core of the current performance indicators. AACC s Voluntary Framework of Accountability, developed with substantial input from ACCT, should inform this effort. These metrics have been defined by community college leaders as those that disclose the most accurate and comprehensive story about the various outcomes for students in credit-bearing programs, including CTE programs. In addition, Perkins postsecondary performance indicators should be aligned, wherever possible and appropriate, with other accountability measures, particularly those in the recently reauthorized Workforce and Innovation Opportunity Act (WIOA). Numerous community colleges are still struggling with the technical skills indicator (1P1) established in the last reauthorization. As written in the statute, the indicator is intended to be flexible due to the fact that specific technical assessments were not always available. While the situation has improved, it remains the case that technical skills assessments, such as industry certifications or licensure exams, do not exist in every program area. Yet, enforcement of this indicator has not been as flexible as envisioned by those involved in drafting the Perkins IV statute. As a result, some colleges report that they are forced to require their students to take certification exams that are not truly appropriate to the programs they are taking. Even in cases where proper assessments exist, colleges often do not have

3 ready access to the results since they are administered by third parties. Our recommendations discontinue this indicator. Funding: Community colleges are concerned with proposals that would move significant funding toward competitive grants. While we could potentially support a proposal to invest additional funding into innovative CTE programs and stronger collaboration, a wholesale shift away from current formula funding would be detrimental for numerous Perkins-funded CTE programs. Many community colleges are smaller, rural institutions that count on the consistency of the Perkins CTE funds they receive, and are comparatively ill-prepared to compete with larger, better-resourced institutions, even despite reassurances that provisions would be made for institutions such as theirs. However, AACC and ACCT strongly support the intent of the competitive grant proposals to maximize support for quality Perkins-funded CTE programs. In order to strengthen program quality, Perkins IV should be modified to increase the minimum requirements for postsecondary program approval at the state level. Community colleges support more robust requirements that demand that a postsecondary institution or consortium truly shows that its CTE programs are designed to meet the needs of (and developed in collaboration with) industry, and that program graduates will be prepared for jobs in high-demand, high-skill and/or high-wage industries. Evidence of industry support may include partnerships or financial contributions, but institutions should also be able to present other indicators as well. Strong partnerships between local educational partners are essential to serving students needs, in particular by providing them with a clear path to their educational and career goals. Community colleges continue to be very supportive of the Programs of Study requirement in Perkins IV, and would support strengthening this provisionin Perkins V. However, the reauthorized legislation must also continue to account for the fact that students in postsecondary CTE programs are not just those that have recently graduated from high school, but also a strong component of adult students (the average community college student is 28). Many community colleges use Perkins funds to support programs specifically tailored to older students that have been in the workforce, a growing number of which are employing innovative strategies such as competency-based education and credit for prior learning. Some CTE programs are heavily populated by older students that already have a postsecondary credential, including those with bachelor s degrees. Perkins must be able to support this increasingly important lifetime learning. We are concerned that requiring secondary-postsecondary consortia would put a significant focus on funding activities that exclusively support students making the transition from high school to college. Therefore, we recommend that Perkins V take the step of facilitating, but not requiring, the formation of consortia. Integration with Other Programs: Program integration is vital if community colleges are to succeed in meeting the educational and training needs of the diverse populations that they serve. Congress has the unique opportunity to

4 increase the alignment between Perkins, WIOA, the Elementary and Secondary Education Act and the Higher Education Act. First and foremost, to the greatest extent possible, the accountability measures in these statutes as they apply to community colleges should be identical where possible. Community college administrators continue to experience difficulties with metrics that are similar, but not quite the same, from program to program. While the particular emphases of these particular programs differ, the overarching goal of a better-educated current and future workforce applies to all of them. This should manifest itself in clear, outcomes-based metrics that best reflect the various successful outcomes that community college students experience, from obtaining certificates and associate degrees, to transfer to four-year institutions and gaining employment. As noted above, community colleges have developed a set of metrics in the Voluntary Framework for Accountability that achieve these purposes, and they should be incorporated into these bills as appropriate. Community colleges are increasingly employing integrated instruction and other strategies to accelerate the path to a postsecondary credential for low-skilled students. The postsecondary completion goals laid out by President Obama, leading foundations, and our associations cannot be achieved without concerted efforts to help those with the most academic needs. Yet, too often local institutions have faced difficulty combining federal resources to most effectively serve these students. Perkins V should explicitly support these activities at the state and local level. Community colleges also support unified state and local plans addressing, at the least, WIOA Title I, adult basic education (WIOA Title II), and the Perkins Act. This will help bring together individuals who should be working together towards common ends, but are too often working in separate silos, including within our member institutions. Reforming Title II: In fiscal year 2011, Congress ended separate federal support for state grants under Tech-Prep. The program had been in place for two decades and used to support consortia of secondary and postsecondary educational institutions. AACC and ACCT believe that it is important to reemphasize the elements and intent of Tech-Prep in Perkins V, and that Congress should reform Title II to support innovative, evidence based programs supporting the needs of business and industry. In 2005, the Department of Labor awarded its first round of grants under President Bush s Community-Based Job Training Grants program. The aim was to support capacity at community colleges in providing training for individuals in high-growth and high-demand industries. It was an economic driven approach designed to meet the needs of business and industry. The program was renamed under President Obama, but ultimately funding was eliminated in 2011 in favor of a $2 billion mandatory investment in the Trade Adjustment Assistance Community College and Career Training (TAACCCT) Grant program. Those funds ran out in 2015 after four rounds of competitive grants. With the end of mandatory funding support for TAACCCT there is now a dearth of federal financial support for these types of business and industry partnerships with community colleges.

5 There have been recent proposals to continue support for this area, including the Community College to Career Fund and the American Technical Training Fund. Given the past bipartisan support of this type of program and need to support these industry partnerships, AACC and ACCT request Congress s consideration to revise Title II to support innovation and partnerships between business and providers of career and technical education. We thank you for your consideration, and would like to also offer the following legislative language recommendations.

6 Legislative Language Recommendations SEC. 3. DEFINITIONS. [Insert in the appropriate place the following definition:] (X) Recognized postsecondary credential The term recognized postsecondary credential has the meaning given the term in section 3 of the Workforce Innovation and Opportunity Act of SEC ACCOUNTABILITY. [Modify paragraph (B) to read as follows:] (B) CORE INDICATORS OF PERFORMANCE FOR CAREER AND TECHNICAL EDUCATION STUDENTS AT THE POSTSECONDARY LEVEL. Each eligible agency shall identify in the State plan core indicators of performance for career and technical education students at the postsecondary level that are valid and reliable, and that include measures of each of the following: (i) (ii) (iii) The percentage of CTE concentrators who obtain a recognized postsecondary credential, during participation in or within 1 year after exit from postsecondary education. The percentage of CTE concentrators not obtaining recognized postsecondary credentials who persist in postsecondary education the following year. The percentage of CTE concentrators who earn a recognized postsecondary credential and exit postsecondary education who are in unsubsidized employment during the second quarter after exit from postsecondary education. SEC OCCUPATIONAL AND EMPLOYMENT INFORMATION (c) State level activities. [Insert the following after fields and before the semicolon:], including through the placement of counselors from postsecondary educational institutions in secondary schools. SEC State Plans. (c) Plan contents. [Insert in the appropriate place the following paragraph:]

7 (x) describe how the eligible agency will facilitate the coordinated transition between secondary and sub- baccalaureate postsecondary educational institutions and subbaccalaureate and baccalaureate postsecondary educational institutions. This may include: (d) Plan options. (A) agreements among secondary and postsecondary education systems supporting dual enrollment, dual credit, or articulated credit; (B) support for stackable credentials and career pathways developed and implemented pursuant to section (d)(3)(B) of the Workforce Innovation and Opportunity Act of [Insert in the appropriate place the following paragraph:] (x) An eligible agency may submit a combined plan coordinated with the Workforce Innovation and Opportunity Act of 2014 which includes all requirements under subsection (c); Sec STATE LEADERSHIP ACTIVITIES. (c) Permissible use of funds. [Modify paragraph (12) to read as follows:] (12) - providing career and technical education programs for adults and school dropouts to complete their secondary school education, in coordination, to the extent practicable, with activities authorized under the Adult Education and Family Literacy Act and career pathways developed and implemented pursuant to section (d)(3)(B) of the Workforce Innovation and Opportunity Act of 2014; SEC LOCAL PLAN FOR CAREER AND TECHNICAL EDUCATION PROGRAMS (b) Contents. [Insert the following new paragraph in the appropriate place:] (x) For postsecondary recipients, demonstrate how the eligible recipient will ensure funds will be used to support programs that are aligned with the workforce needs of industry at the local, regional or statewide level. (A) Such demonstration shall include: (i) direct consultation with businesses and industry groups, including through program and institutional industry advisory boards, participation in sector-based partnership

8 initiatives, consultation with local workforce development boards, or other means of communicating with local and regional employers. (ii) use of labor market information, such as provided under Section 15(e)(2) 35 of the Wagner-Peyser Act (29 U.S.C. 49l-2(e)(2)) or other sources, including nongovernmental sources and employment projections by local and regional employers, to inform the development and modification of supported programs to remain aligned with industry needs. (B) Such demonstration may include: (i) Opportunities for students to engage in internships or other work-based learning opportunities with local and regional employers as a part of their educational program. (ii) Commitments by local and regional employers to hire students from supported programs. (iii) Direct participation of local and regional businesses in the provision of the educational program, including through donation of equipment an employee time. (iv) Other indicia of business and industry involvement with the supported program. SEC LOCAL USES OF FUNDS. (c) Permissive. [Insert in the appropriate place the following new paragraph:] (x) at the postsecondary level, to develop and support programs that provide concurrent and integrated provision of basic skills instruction in career and technical education courses.

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