Audience: Policymaker & Administrator

Agencies and organizations in the workforce system use assessments to meet institutional needs in two ways—to determine a person’s eligibility for services and to document achievement of program goals. Large and small organizations can benefit from developing assessment practices and policies to utilize existing resources, including funding, effectively. Examining assessment issues with an organizational perspective will help to support the establishment of a coordinated system of assessment services, improve system capacity, foster interagency cooperation, streamline the delivery of quality assessment services at the state, regional, or local organizational levels.

Workforce development services vary extensively across states and communities. Variations in services and providers create a particularly challenging context for the provision of quality assessment services to youth, especially at-risk populations such as youth with disabilities. Publicly funded organizations, both state and local, charged with providing assessment services find that they must navigate a complex maze of laws, regulations, and policies in order to make decisions about these services. Assessment decisions are further constrained by funding concerns, lack of knowledge of available assessment resources, staff inexperience with certain assessments or types of assessment tools, privacy protections, and reporting and evaluation requirements. However, assessment forms the basis upon which educational, vocational, and employment-planning decisions may be made. Also , assessment promotes self-knowledge and awareness of postsecondary options and opportunities for youth. Therefore, it is important to make assessment a core part of the infrastructure of the workforce development system.

Federal legislation related to transition provides an impetus for convening stakeholders and service providers at the state and local levels to improve workforce development services to job seekers and employers. Collaborative, cross-agency cooperation (both statewide and in local communities) is becoming necessary to maximize available expertise and to leverage funding for youth service delivery. Resource mapping, a type of environmental scanning, is a useful means of identifying, recording, and disseminating related resources and services that comprise this delivery system. By detailing current capacities, needs, and expertise, an organization or group of organizations can begin to make strategic decisions about ways to broaden their collective assessment capacity. Resource mapping also allows states and communities to identify service gaps and service overlaps. This information is essential to aligning assessment services and to strategic planning.

Once the organizations providing assessment services are identified and a plan evolves to align assessment services, understandings or agreements between agencies will need to be developed to ensure that assessment services are provided as planned. A legal document such as a Memorandum of Understanding (MOU) can be the tool to detail the work and fiscal responsibilities of participating parties. An assessment services MOU would need to address details regarding who is providing what services, how much they will cost, who is paying for them, where they will be delivered, agreed-upon policies and procedures, and additional information as needed. Confidentiality, privacy issues, and ethics should also be addressed in resource mapping and the development of MOUs to ensure that the provision of assessment and testing services are ethical and fair to all participants. An MOU should be flexible but clear about responsibilities and should be amendable when new issues arise or new service providers become available. Table 4.1 lists the elements commonly found in MOUs and discusses assessment issues that should be considered for inclusion in an MOU.

States and localities that have completed the assessment resource mapping and strategic planning process and have the appropriate interagency agreements in place should be well on their way to developing a coordinated assessment services system. Table 4.2 summarizes the general roles and responsibilities in such a system.

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Questions

1. How does resource-mapping work?

NCWD/Youth has developed a sample format for resource mapping, a type of environmental scan that will create a large-scale portrait of assessment services that can be used for service analysis and ultimately strategic planning and partnerships. The beginning point is to identify providers of assessment services and then collect data on the services provided, target populations, funding, existing partners, and other relevant data. This information is analyzed to identify service gaps and overlaps, funding problems, target populations in need, barriers to aligning services, quick fixes, corrective action, and other issues. The results of the analysis are in turn used to develop or update strategic plans.

Resource mapping is especially useful in resolving funding issues, since half the battle is knowing which organizations are doing what, what fiscal resources are dedicated to assessment, and where assessment service gaps and overlaps exist. Once that information is laid out, interagency agreements can be developed to specify which agencies will provide different types of assessment. Resource mapping and strategic planning processes should incorporate program evaluation and reporting requirements for assessment services.The often-elaborate reporting requirements of federally funded partners will need to be factored into data sharing and data management agreements.

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2. How can organizations and agencies jointly fund assessment activities while maintaining separate funding streams?

When organizations agree to work together, deciding who will pay for assessments is complicated since funding is generally tied to individual participants who meet specific eligibility criteria. Because some assessments can be very expensive, clear criteria for expenditures are needed. Explicit processes should ensure that (a) prior assessments are reviewed and used if appropriate and up-to-date; (b) maximum use is made of the expertise within each agency (e.g. a rehabilitation counselor’s knowledge of disability-related assessments, availability of certified vocational evaluators in the area, etc.); and (c) cost-sharing options are explored across the range of assessments needed. Regulations and policies regarding funding must be detailed from the start through the resource mapping exercise in order to promote clarity, eliminate confusion, and avoid duplication or gaps in services for targeted youth.

A braided funding strategy is useful, particularly in One-Stops where several agencies may be co-located, since it allows the mixing of services without the commingling of funds . Braiding is a financial management process in which collaborating members designate the use of funds from each partner for the provision of specific services. Partners maintain control of their own funds rather than pooling them, which makes reporting easier and reduces turf disputes.

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3. What are the organizational issues relating to ethics, confidentiality, and privacy in providing assessment services?

Policy guidelines, codes of ethics, and written organizational procedures help ensure that assessment and other services are provided in an ethical and fair manner and that partners, administrators, and staff have the same frame of reference for decision-making. Fortunately, organizations don’t have to reinvent the wheel in developing these guidelines. Many professional organizations that work with youth or youth with disabilities have codes of ethics and standards of practice that may be used as models. Some examples are the Code of Professional Ethics and Practicesdeveloped by the National Association of Workforce Development Professionals and the Code of Fair Testing Practices in Education developed by the Joint Committee on Testing.

Policymakers, educators, and other youth service providers should have a working knowledge of the federal and state data privacy laws and regulations governing the operations of their respective organizations. This knowledge should include formal data management policies regulating the following: (a) storage, protection, and security of confidential youth information; (b) receipt and sharing of youth information; (c) the intended uses of privileged information; (d) procedures for obtaining written authorization from the youth (or family members) regarding the receipt, sharing, and use of information; (e) prevention of potential misuses of confidential information; and (f) destruction of electronic and written records after defined time intervals.

Federal data privacy laws include the Family Educational Rights and Privacy Act (FERPA), the privacy standards of the Health Insurance Portability and Accountability Act (HIPAA), the confidentiality requirements of the Workforce Investment Act, and Americans with Disabilities Act. Additionally, many states have enacted data privacy laws to protect individuals from misuse of confidential information by public and private entities. In general, private and confidential information about youth may not be shared or used in any form without the express written consent of the affected individuals and those who are authorized to represent them.

The challenges in establishing and maintaining professional guidelines for ethics, confidentiality, and privacy can be formidable, starting with determining which laws and regulations govern the organization’s operations. Outside resources may need to be brought in to help develop internal policies and procedures and to provide training and initial support for staff.

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Resources

Youth Development Projects & Resources at the Academy for Educational Development
http://www.aed.org/Youth/US/development.cfm
The Academy for Educational Development offers many ways to create and strengthen the infrastructures that support positive development for all youth in America. Policy formulation is one of several foci of the Center.

New York Association of Training and Employment Professionals (NYATEP)
http://www.nyatep.org/pubsresources/samplemous.html
Examples of memoranda of understanding and resource agreements.

U.S. Department of Education FERPA Policy Guidance
http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html
Assistance in understanding the Family Educational Rights and Privacy Act.

HIPAA Privacy Rule and HIPAA Decision Tool
http://www.hhs.gov/ocr/hipaa and http://www.cms.hhs.gov/hipaa/hipaa2/support/tools/decisionsupport/default.asp
Contains information on the Health Insurance Portability and Accountability Act and a decision-making tool for determining if an organization is a covered entity under the Standards for Privacy of Individually Identifiable Health Information (Privacy Rule).

Americans with Disabilities Act Home Page
http://www.usdoj.gov/crt/ada/
Contains a variety of resources for businesses, non-profits, service providers and state and local governments including a link to the law itself.

National Center on Secondary Education and Transition
http://www.ncset.org
Contains policy updates summarizing recent laws and federal regulations, research to practice briefs for improving secondary education and transition services, issue briefs examining current challenges, and data briefs from the National Longitudinal Transition Study 2.

Section 188 Disability Checklist
http://www.dol.gov/oasam/programs/crc/section188.htm
Checklist from the Office of Disability Employment Policy, U.S. Department of Labor, to assist service providers, One-Stop Centers, and other WIA-funded entities with compliance in conducting initial interviews, administering assessments, and providing other services.

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References

American Educational Research Association, American Psychological Association, & National Council on Measurement in Education. (1999). Standards for educational and psychological testing. Washington , DC : American Educational Research Association.

Crane, K. & Skinner, B. (2003). Community resource mapping: A strategy for promoting successful transition for youth with disabilities. Retrieved October 2, 2003, from http://www.ncset.org/publications/viewdesc.asp?id=939.

Joint Committee on Testing Practices. (1988). Code of fair testing practices in education. Washington, DC: Author. Retrieved December 4, 2003, from http://www.csteep.bc.edu/CTESTWEB/documents/related/fairtestcode.pdf .

Minnesota System of Interagency Coordination. (2002). Developing an interagency structure for local coordination of services: Governance manual. Retrieved January 12, 2004 , from http://www.mnsic.org/products/governance.pdf .

National Collaborative on Workforce and Disabilities/Youth. (2004). Making the connections: Growing and supporting new organizations—Intermediaries PDF icon. Retrieved May 6, 2004, from /topic.

Parker, R.M., & Schaller, J.L. (1996). Issues in vocational assessment and disability. In Szymanski, E.M. & Parker, E.M. (Eds.). Work and disability: Issues and strategies in career development and job placement (pp. 127-164). Austin , TX : Pro-Ed.

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