1205-0448 Non Substantive Change Justification

Non-Substantiative Change Request

OMB Control Number 1205-0448 – WIOA Joint Quarterly Narrative Performance Report Template

Expiration Date: 07/31/2027

Proposed Changes

To apply the implementation of Executive Order 14151 Ending Radical and Wasteful Government DEI Programs and Preferencing to the WIOA Joint Quarterly Narrative Performance Report Template based on the guidance provided.

The proposed changes involve deleting statements relating to “equity” in the three places they were referenced within the template. These changes include:

• Delete the second paragraph of Section IV. Development and Implementation of Effective Practices and Program Model Strategies, which states: “This section may also reflect how equity is taken into account in the development and implementation of the program. “Equity” means the consistent and systematic fair, just, and impartial treatment of all individuals, including individuals who belong to underserved communities that have been denied such treatment. The term “underserved communities” refers to populations sharing a particular characteristic, as well as geographic communities that have been systematically denied a full opportunity to participate in aspects of economic, social, and civic life.”

• Delete Subparagraph B of Section IV., which states: “Grantees may describe how any development and implementation activities (such as those outlined above in Section IV.A) contribute to use of services by underserved populations and facilitate equitable service provisions across target populations and underserved communities. Grantees may also identify administrative barriers, statutory barriers, or other challenges they face in ensuring equitable use, service delivery and outcomes achieved.”

• Delete the last sentence of Section VII. Status Update on Employer Engagement Strategies, which states: “This section may discuss how equity is taken into account in the identification of, engagement with, and services provided to employers and employer associations.”

Purpose of Collection

The Employment and Training Administration administers Titles I and III of the Workforce Innovation and Opportunity Act (WIOA), which includes specific reporting requirements that are shared across the programs authorized under the law. For the non-formula, competitive grant programs that are now using the QNR, prior to the Joint Quarterly Narrative Performance Report (QNR), these programs were reporting inconsistent data and did not have a uniform manner in which to submit QNR information. Using a shared narrative template furthers the WIOA legislative requirements and ensures that grantees are fully describing WIOA-related activities that ensure strong performance management. Additionally, the use of a joint narrative report template also ensures that each of the grant programs is meeting the Uniform Guidance requirements related to narrative grant reporting as laid out in the Final Rule on Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, which streamlined the federal government's guidance on grant management and placed requirements on specific information that grantees should report to their federal funders.

The QNR provides additional information beyond what the Quarterly Performance Report provides. The QPR gives aggregated performance data on participants and related outcomes. The QNR provides complementary and contextual insights through a detailed account of program activities, accomplishments, and narrative information on progress toward performance outcomes during the quarter. It also provides information on grant challenges and timeline progress, as well as the opportunity to share success stories.

Additionally, the use of standardized narrative reports supports WIOA implementation and assists in identifying areas of compliance challenges consistently across the discretionary programs that are reporting on WIOA performance indicators. The use of a consistent narrative template furthers the goals of WIOA around system alignment and consistency of reporting, which helps to improve the quality of performance information that is received by ETA.