    Workforce Investment Act: Labor Has Taken Several Actions to
    Facilitate Access to One-Stops for Persons with Disabilities, but
    These Efforts May Not Be Sufficient (14-DEC-04, GAO-05-54).

    The Workforce Investment Act (WIA) of 1998 includes provisions
    intended to ensure that people with disabilities have equal
    opportunity to participate in and benefit from the programs and
    activities offered through one-stop career centers (one-stops).
    But little is known, and questions have been raised, about how
    well this system is working for persons with disabilities. This
    report examines (1) what the Department of Labor (Labor), states,
    and the one-stops have done to facilitate comprehensive access to
    the WIA one-stop system; (2) the various relationships that the
    one-stops have established with disability-related agencies to
    provide services to persons with disabilities; (3) what Labor has
    done to ensure that the one-stops are meeting the comprehensive
    access requirements, and the factors that have affected efforts
    to ensure compliance; and (4) what is known about the employment
    outcomes of persons with disabilities who use the one-stop
    system.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-05-54
        ACCNO:   A14397
      TITLE:     Workforce Investment Act: Labor Has Taken Several Actions
    to Facilitate Access to One-Stops for Persons with Disabilities,
    but These Efforts May Not Be Sufficient
         DATE:   12/14/2004
      SUBJECT:   Aid for the disabled
    	     Employment of the disabled
    	     Employment or training programs
    	     Performance measures
    	     Persons with disabilities
    	     Program evaluation
    	     Workfare
    	     Intergovernmental relations
    	     Noncompliance
    	     Federal aid programs
    	     Locally administered programs
    	     State-administered programs
    	     California
    	     Illinois
    	     Massachusetts
    	     Mississippi
    	     New Mexico
    	     Tennessee
    	     Dept. of Education Vocational
    	     Rehabilitation Program

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    GAO-05-54

         * Results in Brief
         * Background
         * Labor, Local Areas, and One-Stops Have Made Various Efforts and
           Degrees \of Progress in Facilitating Access
              * Federal Grants Have Provided Funding to Facilitate One-Stop
                Accessibilit\y
              * Local Areas and One-Stops Have Made對 Efforts to Fa
         * One-Stops and Disability Agencies Have Established Various
           Relationships\ to Serve Persons with Disabilities
         * Labor Has Taken Actions to Ensure That One-Stops Comply with Access
           Requ\irements, but These Efforts May Not Be Sufficient
         * Information on Employment Outcomes Is Limited
         * Conclusions
         * Recommendation
         * Agency Comments
         * Appendix I: Comments from the Department of Labor
         * Appendix II: GAO Contacts and Staff Acknowledgments
         * GAO Contacts
         * Staff Acknowledgments
         * Related GAO Products
              * Order by Mail or Phone

                     United States Government Accountability Office

    Report to Congressional Requesters

    GAO

    December 2004

    WORKFORCE INVESTMENT ACT

     Labor Has Taken Several Actions to Facilitate Access to One-Stops for Persons
               with Disabilities, but These Efforts May Not Be Sufficient

    GAO-05-54

    WORKFORCE INVESTMENT ACT

    Labor Has Taken Several Actions to Facilitate Access to One-Stops for
    Persons with Disabilities, but These Efforts May Not Be Sufficient

      What GAO Found

    Labor has awarded grants to facilitate comprehensive access, which is
    defined in this report as providing people with disabilities the equal
    opportunity to participate in and benefit from the programs, activities,
    and/or employment offered by the WIA one-stop system. States and local
    areas have used these grants for a range of efforts, including increasing
    staff capacity to provide services to persons with disabilities. During
    our site visits to 18 local areas and one-stops, we found that officials
    at most sites were working to implement architectural access requirements.
    Moreover, local areas and one-stops varied in the degree to which they had
    addressed other areas of comprehensive access. For example, a few sites
    had only begun to acquire assistive technology devices; other sites had
    assistive technology and had trained some or all of their staff in how to
    use it.

    One-stops have established various relationships to provide services to
    persons with disabilities. The structure of the one-stops' relationships
    with state vocational rehabilitation (VR) programs varied, as did the
    extent to which they have formed relationships with disability-related
    service providers other than VR. A few local areas and one-stops primarily
    formed relationships with VR, while others had also formed relationships
    with community-based disability organizations.

    Although Labor has taken several actions to ensure comprehensive access to
    one-stops, these efforts may not be sufficient. Labor's Employment and
    Training Administration (ETA), Civil Rights Center (CRC), and Office of
    Disability Employment Policy (ODEP) have issued guidance and assistance on
    the regulatory requirements. CRC also has conducted on-site reviews at
    local areas and one-stops in two large metropolitan areas in two states.
    In both areas, CRC identified instances of noncompliance with these
    requirements. Reviews in two other states will be completed during fiscal
    year 2005, but Labor has not developed a long-range plan for how it will
    carry out its oversight and enforcement responsibilities beyond 2005. To
    date, CRC's monitoring and enforcement efforts account for less than 2
    percent of the total number of local areas and one-stops nationwide. The
    CRC Director stated that she had not yet determined whether CRC would
    conduct additional on-site reviews.

    The information that Labor publishes on employment outcomes for people
    with disabilities is limited for a variety of reasons. Disclosure about
    disability status is voluntary, thus the information about employment
    outcomes may be misleading. The collection of information on the
    employment outcomes of WIA participants is limited to those who are
    registered for services, and one-stops are not required to register
    customers who participate in self-service or informational activities. The
    performance measurement system may result in customers being denied
    services because local areas may be reluctant to provide WIA-funded
    services to job seekers who may be less likely to find employment.

                     United States Government Accountability Office

    Contents

      Letter 1

    Results in Brief 5 Background 8 Labor, Local Areas, and One-Stops Have
    Made Various Efforts and

    Degrees of Progress in Facilitating Access 15 One-Stops and Disability
    Agencies Have Established Various

    Relationships to Serve Persons with Disabilities 26 Labor Has Taken
    Actions to Ensure That One-Stops Comply with

    Access Requirements, but These Efforts May Not Be Sufficient 28
    Information on Employment Outcomes Is Limited 31 Conclusions 33
    Recommendation 34 Agency Comments 34

    Appendix I Comments from the Department of Labor

      Appendix II GAO Contacts and Staff Acknowledgments 51

    GAO Contacts 51 Staff Acknowledgments 51

    GAO's Related Products

      Tables

    Table 1: WIA's Mandatory One-Stop Partner Programs and Related Federal
    Agencies 9 Table 2: Work Incentive Grants: 2000, 2002, 2003, and 2004 16
    Table 3: Selected Types of Auxiliary Aids and Services 20 Table 4:
    Co-location Status of VR Staff in the One-Stops We Visited 26

      Figure

    Figure 1: GAO Site Visits to Local Areas and One-Stop Centers

    Page i GAO-05-54 Workforce Investment Act

    Abbreviations

    ADAAG            Americans with Disabilities Act Accessibility Guidelines
                      for Buildings and Facilities
    CRC            Civil Rights Center
    ETA            Employment and Training Administration
    EO             equal opportunity
    HUD            Department of Housing and Urban Development
    JTPA           Job Training Partnership Act
    MOA            Methods of Administration
    ODEP           Office of Disability Employment Policy
    SSA            Social Security Administration
    TDD            telecommunications device for the deaf
    TTY            text telephone
    UFAS           Uniform Federal Accessibility Standards
    VR             Vocational Rehabilitation
    WIA            Workforce Investment Act
    WIG            Work Incentive Grant

    This is a work of the U.S. government and is not subject to copyright
    protection in the United States. It may be reproduced and distributed in
    its entirety without further permission from GAO. However, because this
    work may contain copyrighted images or other material, permission from the
    copyright holder may be necessary if you wish to reproduce this material
    separately.

    United States Government Accountability Office Washington, DC 20548

    December 14, 2004

    The Honorable Judd Gregg, Chairman Committee on Health, Education, Labor,
    and Pensions United States Senate

    The Honorable Edward M. Kennedy Ranking Minority Member Committee on
    Health, Education, Labor, and Pensions United States Senate

    The Honorable Tom Harkin United States Senate

    The ability to engage in productive employment is the cornerstone of the
    American workforce system, and the programs and services provided through
    the Workforce Investment Act (WIA) of 1998 are intended for persons with
    and without disabilities. WIA unifies previously fragmented employment and
    training programs and creates a more comprehensive workforce investment
    system by bringing together over $15 billion of federally funded programs
    into a single service delivery system-the onestop center system. WIA
    requires about 17 programs to provide services through the one-stop
    system, including the Department of Education's Vocational Rehabilitation
    (VR) program, which provides services to eligible individuals with
    disabilities. The Department of Labor (Labor) is responsible for providing
    general leadership and guidance to the one-stop system. Within Labor, the
    Civil Rights Center (CRC) and the Employment and Training Administration
    (ETA) each have a role in ensuring that people with disabilities can
    participate in and benefit from the programs and services provided through
    the one-stop system. Additionally, Labor's Office of Disability Employment
    Policy (ODEP) has a role in increasing employment opportunities for people
    with disabilities.

    Section 188 of WIA, among other things, prohibits discrimination on the
    basis of disability with respect to the programs funded or otherwise
    financially assisted under WIA. Labor's regulations implementing WIA
    Section 188 include specific provisions intended to ensure that persons
    with mobility, mental health, hearing, vision, speech, cognitive, or other
    impairments have equal opportunity to participate in or be employed by the
    programs and activities offered through the one-stop system. These
    regulations encompass provisions that oblige recipients of WIA financial
    assistance to take positive actions to provide people with disabilities
    the equal opportunity to participate in and benefit from the programs,
    activities, and/or employment offered by the one-stop system. For the
    purpose of this report, we use the term comprehensive access when
    referring to these requirements. These requirements include actions such
    as providing architectural access, program accessibility, reasonable
    accommodations or modifications, service delivery in integrated settings,
    and effective communication. Labor's regulations also include provisions
    prohibiting covered recipients of federal financial assistance from taking
    discriminatory actions that exclude people with disabilities from
    participating in the programs, activities, or employment offered by the
    one-stop career center system, and provisions requiring recipients to
    establish the administrative structure that CRC views as necessary in
    order to ensure nondiscrimination and equal opportunity for members of all
    groups protected by Section 188 of WIA.

    Despite the requirements contained in these provisions, little is known
    about how well the one-stop system is working for people with
    disabilities. As a result, you asked us to examine (1) what Labor, states,
    and the onestop centers have done to facilitate comprehensive access to
    the WIA onestop system; (2) the various relationships that the one-stop
    centers have established with disability-related agencies to provide
    services to persons with disabilities; (3) what Labor has done to ensure
    that the one-stop centers are meeting the comprehensive access
    requirements, and the factors that have affected efforts to ensure
    compliance; and (4) what is known about the employment outcomes of persons
    with disabilities who use the one-stop system.

    To address these issues, we interviewed officials at Labor, and we
    conducted document reviews of Labor's Work Incentive Grants (WIG) and the
    Disability Program Navigator (Navigator) grants. 1 The Work Incentive
    Grants are designed to enhance the employment and career advancement of
    people with disabilities. The Navigator grants are intended to increase
    employment and self-sufficiency of people with disabilities. We used
    information obtained from these grants to help select which states, local

    The WIG and Navigator grants do not represent all of Labor's grants for
    disability-related activities. For example, the Office of Disability
    Employment Policy (ODEP) also provides grants for serving customers with
    disabilities in the WIA one-stop system, including grants that focus on
    providing customized employment strategies to create opportunities for
    individuals with disabilities and improving school-to-work transition
    outcomes for youth with disabilities.

        Page 2 GAO-05-54 Workforce Investment Act

    areas, and full-service one-stop career centers (one-stops) to visit. We
    selected these states on the basis of geographical dispersion, as well as
    whether they received one or more types of grants, if any. We conducted
    site visits to six states-California, Illinois, Massachusetts,
    Mississippi, New Mexico, and Tennessee. We visited three local workforce
    investment areas (local areas) and associated one-stop centers in each of
    these states. After discussions with WIA officials within the six states,
    we selected the local areas and one-stop centers to obtain both urban and
    suburban centers and, where possible, one-stop centers in small towns or
    rural areas. Figure 1 shows the 18 locations we visited. At the local
    workforce investment area and one-stop centers, we interviewed WIA
    officials, onestop staff, and officials from organizations representing
    people with disabilities about issues and practices for providing
    programs, services, and activities to individuals with disabilities.
    Additionally, we reviewed relevant documents from Labor, as well as the
    WIA statute and regulations and other relevant statutory and regulatory
    provisions.

    Figure 1: GAO Site Visits to Local Areas and One-Stop Centers

    While WIA and its implementing regulations require that persons with
    disabilities can use the one-stop facilities and participate in and
    benefit from the system's programs, activities, and services, we did not
    assess the extent to which the approximately 1,900 one-stops, located in
    about 600 local areas nationwide, meet the comprehensive access
    requirements. Determining whether a particular site meets architectural
    access standards is fairly straightforward, but this is not the case with
    determining whether other comprehensive access requirements have been met.
    While many of the elements of these requirements, such as provision

                                    Results in Brief

    of assistive technology devices, are described in existing regulations,
    the regulations allow one-stops to use a variety of methods to meet the
    requirements. Because there is no one list of methods that covers all
    paths to comprehensive accessibility, it is a complex and
    resource-intensive task to determine whether the comprehensive access
    requirements have been met. Determining whether a single one-stop center
    is in compliance with these requirements requires both on-site
    observations of the facility and its equipment, as well as extensive
    document reviews and interviews with one-stop staff. Determining whether
    one-stops are in compliance with comprehensive access requirements on a
    nationwide basis was beyond the scope of this study.

    We conducted our work between September 2003 and October 2004 in
    accordance with generally accepted government auditing standards.

    Labor has awarded grants to facilitate comprehensive access to employment
    and training programs for persons with disabilities, and local areas and
    one-stop centers have also made numerous efforts, as well as various
    degrees of progress, in facilitating comprehensive access to their
    programs and services. Specifically, Labor's Employment and Training
    Administration has awarded states and local entities over 100 grants
    totaling $80 million for disability-related activities, such as enhancing
    comprehensive access to the one-stops. States and local areas have used
    these grants for a range of efforts, including assessing one-stop
    architectural accessibility, acquiring assistive technology devices, and
    increasing staff capacity to provide services to persons with
    disabilities. During our site visits to 18 local areas and their
    one-stops, we found that officials in most sites were working to implement
    architectural access requirements. Some of these officials told us that
    they had made at least some changes to improve architectural access. For
    example, some changes included installing signage and electric door
    openers. However, we found that the local areas and one-stops we visited
    varied in the degree to which they had addressed other comprehensive
    access concerns. For example, a few sites had only begun to acquire
    assistive technology devices, while other sites had assistive technology
    devices and had trained some or all of their staff in how to use them.

    One-stops, VR, and other disability-related agencies in the community have
    established various relationships to provide services to persons with
    disabilities. From our site visits, we found that the structure of the
    onestop centers' relationships with VR varied, particularly in terms of
    whether co-location was occurring. While most of the one-stops we visited
    had VR staff on-site at least part of the time, four of the sites we
    visited had no onsite VR staff. Officials from the sites at which full- or
    part-time co-location of VR staff was taking place said that co-location
    was beneficial because, among other reasons, it helped the one-stop staff
    provide faster and less fragmented services to persons with disabilities.
    For those locations at which VR was not on-site, officials told us that
    there were a variety of reasons for this, such as a lack of space in the
    one-stop. The one-stop centers we visited also varied in terms of the
    extent to which they formed relationships with disability-related service
    providers other than VR. In a few cases, local areas and one-stops
    primarily formed relationships with VR. However, other local areas and
    one-stops we visited had also formed relationships with one or more
    disability-related organizations in the community, such as independent
    living centers, mental health agencies, and cognitive/developmental
    disability agencies. Officials from local areas and their one-stops, as
    well as those from VR and community disability agencies, cited a range of
    benefits to being able to refer their customers to one another for
    services, when it was appropriate to do so. For example, some local area
    and one-stop officials said the one-stop's relationship with VR allowed
    the two agencies to combine their resources to maximize the services they
    can provide to their customers.

    Labor has taken several actions to ensure comprehensive access to onestops
    by persons with disabilities, but these efforts may not be sufficient. For
    instance, Labor has not only funded grants, it has also provided training
    in ways to facilitate comprehensive access in the one-stop centers.
    Further, within Labor, CRC, along with ETA and ODEP, has provided guidance
    and assistance to one-stops on accommodations and other comprehensive
    access requirements. In addition, CRC has responsibility for interpreting,
    monitoring, and enforcing WIA's statutory and regulatory
    nondiscrimination, comprehensive access, and administrative provisions.
    One key method Labor uses to ensure adherence to these provisions has been
    to require that each state's governor sign a plan, known as the Methods of
    Administration (MOA), that describes the policies, procedures, and systems
    that each state has established to ensure adherence with WIA's statutory
    and regulatory requirements. In addition, in 2003, CRC completed its first
    phase of on-site reviews at local workforce areas and one-stops in two
    large metropolitan areas in two states, Miami/Dade County, Florida, and
    New York City, New York. In both metropolitan areas it reviewed, CRC
    identified instances of noncompliance with WIA's comprehensive access and
    other requirements, including the existence of barriers limiting services
    to persons with disabilities. On the basis of its findings, CRC required
    the two states to provide it with written responses of the corrective
    actions they planned to make. Further, in May 2004, the CRC Director
    requested that all states complete, for themselves and their largest local
    area, a self-assessment tool to assess compliance with the requirements of
    WIA Section 188 and its implementing regulations. CRC anticipates using
    the information provided by the on-site reviews and selfassessments to
    identify exemplary practices as well as areas needing improvement.
    Although Labor has taken actions to address the comprehensive access and
    other requirements for persons with disabilities, these efforts may not be
    sufficient to ensure one-stop system compliance. For instance, although
    CRC plans to complete on-site reviews in two other large metropolitan
    areas in two states during fiscal year 2005, it has not developed a
    long-range plan that describes how it will carry out its oversight and
    enforcement responsibilities beyond 2005. Currently, the CRC reviews that
    have been completed, or are in process, represent less than 2 percent of
    the local areas and one-stop centers nationwide. At the time of our
    review, the CRC Director said that she had not yet determined whether CRC
    would conduct additional on-site reviews.

    Information about the employment outcomes of persons with disabilities is
    limited by the extent to which disability data are collected and overall
    data collection methods under WIA. Although Labor publishes some
    information on employment outcomes for people with disabilities in areas
    such as job placement, employment retention, earnings change, and skill
    attainment for the WIA-funded programs, this information is limited for
    several reasons. One reason is that the information Labor publishes on the
    employment outcomes of persons with disabilities is limited to the
    subpopulation of persons with disabilities who disclose their disability
    status, and therefore the employment outcomes may be misleading for the
    total population of persons with disabilities receiving services through
    WIA. Labor has issued guidance stating that one-stops must inquire about
    disability status from job seekers upon registration for services. Such
    inquiries must be asked of all job seekers, but an individual's decision
    to disclose his or her disability status must be completely voluntary.
    Further, the collection of employment outcome information on WIA
    participants, including information on individuals with disabilities, is
    limited to those individuals who are registered for services. Current law
    does not require that one-stops register job seekers who receive services
    that are selfservice and informational in nature, and thus they are not
    included in the performance measures. Finally, the performance measurement
    system developed under WIA may result in the denial of services to some
    customers because performance levels are tied to incentives and sanctions
    depending on whether states meet these levels. Consequently, local areas
    may be reluctant to provide WIA-funded services to job seekers, including
    persons with disabilities, in situations in which the persons may be
    unlikely to find employment or experience an increase in earnings when
    placed in jobs. In a prior report, we recommended that Labor develop a
    systematic method to account for different populations and local economic
    conditions when negotiating performance levels. 2 Labor agreed with the
    importance of taking economic conditions and characteristics of the
    population into account when setting performance expectations and has
    commissioned a study to address this issue.

    To improve comprehensive access for persons with disabilities to the
    onestop system, we recommend that Labor develop and implement a longterm
    plan for ensuring that the one-stop system complies with the comprehensive
    access requirements for persons with disabilities. In developing such a
    strategy, Labor should utilize the expertise of CRC, ETA, and ODEP staff.
    In commenting on the draft of this report, Labor generally agreed with our
    recommendation and said that even more could be done to ensure
    comprehensive access within the one-stop system.

    The Workforce Investment Act of 1998 requires states and localities to

    bring together about 17 federally funded employment and training services
    into a single system-the one-stop system. Funded through four federal
    agencies, these programs, also known as the mandatory partner programs (or
    more simply, mandatory partners), 3 are to provide services through a
    statewide network of one-stop career centers. (See table 1.)

    2

    GAO, Workforce Investment Act: States and Local Areas Have Developed
    Strategies to Assess Performance, but Labor Could Do More to Help.
    GAO-04-657 (Washington, D.C.: June 1, 2004).

    3

    Co-location of the mandatory partners at the one-stop center is not
    required. Labor has stated that under WIA, one-stop operations can range
    from coordination, co-location, and integration.

    Page 8 GAO-05-54 Workforce Investment Act

    Table 1: WIA's Mandatory One-Stop Partner Programs and Related Federal
    Agencies

                   Federal Agency Mandatory One-Stop Partner Program

                             Department of Labora WIA Adult

                                 WIA Dislocated Worker

                                       WIA Youth

                           Employment Service (Wagner-Peyser)

                          Trade Adjustment Assistance Programs

                       Veterans' Employment and Training Programs

                                 Unemployment Insurance

                                       Job Corps

                         Welfare-to-Work Grant-Funded Programs

                      Senior Community Service Employment Program

    Employment and Training for Migrant and Seasonal Farm Workers

                      Employment and Training for Native Americans

               Department of Education Vocational Rehabilitation Program

                              Adult Education and Literacy

                           Vocational Education (Perkins Act)

    Department of Health and Community Services Block Grant Human Services

    Department of Housing and HUD-administered Employment and Training Urban
    Development (HUD)

    Source: GAO-04-657.

    a

    Labor's Employment and Training Administration (ETA), in collaboration
    with the partner programs, provides general leadership and guidance to the
    one-stop system.

    Three of these 17 programs, which were created and funded by Title I of
    WIA to provide services to adults, dislocated workers, and youth, replace
    those previously funded under the Job Training Partnership Act (JTPA). The
    Department of Labor distributes funds for these three programs to the
    states, and the states in turn distribute funds to designated local areas
    within the states based on formulas prescribed by WIA. WIA also
    established performance measures that states and localities must track in
    order to demonstrate the programs' effectiveness. The performance measures
    primarily focus on entered employment rates, employment retention rates,
    earnings changes, and credential rates. 4

    WIA programs provide for three levels of services for adults and
    dislocated workers: core, intensive, and training. Core services include
    basic services such as job search and labor market information. These
    activities may be self-service or may require some staff assistance.
    Intensive services include such activities as comprehensive assessment and
    case management, which require greater staff involvement. Training
    services include such activities as occupational skills training or
    on-the-job training.

    WIA requires the establishment of workforce investment boards at the state
    level and in local areas. The state boards are responsible for a number of
    functions, including the development and improvement of the statewide
    workforce investment system and the designation of local areas. The state
    board assists in the preparation of the state plan and the annual report,
    both of which are submitted to the Secretary of Labor. The local workforce
    investment board sets policy for the local area, and its specific duties
    include developing a comprehensive 5-year local plan and selecting
    one-stop operators.

    WIA contains a number of provisions to ensure that individuals with
    disabilities are adequately served. The most important of these provisions
    is Section 188, which prohibits any program or activity funded or
    otherwise financially assisted in whole or part under WIA from
    discriminating on the basis of disability as well as race, color,
    religion, sex, national origin, age, or political affiliation or belief. 5

    4

    For more information on WIA's performance measures, see GAO-04-657 and
    GAO, Workforce Investment Act: Improvements Needed in Performance Measures
    to Provide a More Accurate Picture of WIA's Effectiveness. GAO-02-275 (
    Washington, D.C.: February 1, 2002).

    5

    For WIA beneficiaries only, Section 188 also prohibits discrimination on
    the basis of an individual's status as a citizen or national of the United
    States, or as an individual lawfully authorized to work in the United
    States, or on the basis of participation in any WIA Title I financially
    assisted program or activity.

    To help states and local areas implement the Section 188 provisions, the
    Department of Labor issued interim final regulations in November 1999. 6
    These regulations, which have the force of law, describe requirements for
    the recipients of financial assistance under WIA Title I, and for programs
    and activities operated by the one-stop partners as part of the one-stop
    system. 7 The regulations also identify how recipients will be held
    accountable for ensuring nondiscrimination and equal opportunity for
    individuals with disabilities.

    The WIA Section 188 regulations contain certain provisions that prohibit
    recipients of WIA financial assistance from taking certain discriminatory
    actions. For example, recipients must not:

         o provide significant assistance to a person or entity that
           discriminates in providing any aid, benefits, services, or training to
           registrants, applicants, or participants;
         o make a selection for the site or location of a facility that has a
           discriminatory effect; or
         o impose or apply eligibility criteria that screen out or tend to screen
           out individuals with disabilities, unless such criteria are necessary
           for the provision of the aid, benefit, service, training, program, or
           activity being offered.

    Further, WIA Section 188 regulations contain provisions that oblige
    recipients to take certain positive actions to provide comprehensive
    access to WIA programs and services. For example, these regulations
    require some recipients of WIA financial assistance-those who are in
    facilities or parts of facilities that are constructed or altered on their
    behalf-to make those facilities architecturally accessible. In contrast,
    recipients of WIA financial assistance who are in unaltered existing
    facilities are not necessarily required to make those facilities

    6

    See 64 Fed. Reg. 61692. These regulations are found at 29 CFR Part 37 and
    incorporate, by reference, certain portions of the regulations
    implementing Section 504 of the Rehabilitation Act of 1973, as amended,
    pertaining to employment practices and employment-related training,
    architectural and program accessibility and reasonable accommodation.

    7

    WIA Section 188 regulations apply to programs and activities that are
    conducted as part of the one-stop system and operated by one-stop
    partners, regardless of the source of the financial assistance for such
    programs and activities.

    architecturally accessible, but are subject to other requirements for
    accessibility, known as program access, which specify that a recipient
    must operate each service, program, or activity so that it, when viewed in
    its entirety, is readily accessible to and usable by individuals with
    disabilities. Recipients of WIA financial assistance do not have to make
    each of their existing facilities or every part of an existing facility
    accessible to and usable by individuals with disabilities, and can satisfy
    the accessibility requirements for existing facilities by redesigning
    equipment, reassigning services to accessible buildings, assigning aides
    to beneficiaries, and providing home visits, among other options.

    As part of providing comprehensive access, WIA Section 188 regulations
    require recipients of WIA financial assistance to take a number of
    additional actions when administering their programs or activities. Under
    these provisions, recipients must:

         o take steps to ensure that communications with individuals with
           disabilities are as effective as communications with others, including
           providing appropriate auxiliary aids and services where necessary;
         o provide reasonable accommodation to qualified individuals with
           disabilities who are applicants, registrants, or eligible
           applicants/registrants for, or participants in, employees of, or
           applicants for, employment with their programs and activities, unless
           providing the accommodation would cause undue hardship; 8
         o make reasonable modifications in policies, practices, or procedures,
           unless making the modifications would fundamentally alter the nature
           of the service, program, or activity;
         o provide the most integrated setting appropriate to the needs of
           qualified individuals with disabilities; and

    In the one-stop context, the term reasonable accommodation can include
    making existing facilities accessible; restructuring a program, service,
    or training, or the way in which it is provided; part-time or modified
    training schedules; making appropriate adjustments or modifications to
    examinations, training materials, or policies; acquiring or modifying
    equipment and devices; and providing qualified readers and interpreters,
    among other possible actions. One-stops and other recipients are required
    to make a requested accommodation unless providing it would create an
    undue hardship for them, which is defined as "significant difficulty or
    expense," when considered in light of a list of specified factors. The WIA
    Section 188 regulations also require one-stops to make reasonable
    modifications to their policies, practices, or procedures for persons with
    disabilities unless making the modification would fundamentally alter the
    nature of the program or activity.

            * take appropriate steps, such as advertising and marketing, to
              ensure that they are providing universal access to their WIA
              financially assisted programs and activities.
            * The regulations also require recipients of WIA financial assistance
              to establish an administrative structure so that they ensure
              compliance with WIA's nondiscrimination and equal opportunity
              provisions. Each recipient, except small recipients 9 and service
              providers, must designate an equal opportunity (EO) officer who is
              responsible for ensuring that the recipient complies with Section
              188 regulations. EO officers' responsibilities include:
         o monitoring and investigating activities by recipients of WIA financial
           assistance to ensure that they do not violate WIA Section 188
           regulations,
         o reviewing written policies to ensure that those policies are
           nondiscriminatory, and
         o developing and publishing the recipient's procedures for processing
           discrimination complaints.

    Recipients of WIA financial assistance must also provide written
    notification that they do not discriminate on the basis of disability or
    on other prohibited bases. This notification must be placed prominently in
    the facility and distributed through other means. In addition, recipients
    of WIA financial assistance must collect and maintain data necessary to
    allow Labor to determine whether the recipient is complying with Section
    188 of WIA and the implementing regulations. The Director of Labor's Civil
    Rights Center determines which data are necessary.

    Under WIA Section 188 regulations, the governor of each state is
    responsible for, among other things:

    o  oversight of all WIA financially assisted state programs,

    o  ensuring compliance with WIA Section 188 and its implementing
    regulations, and

    A small recipient is one that serves a total of fewer than 15
    beneficiaries during a grant year and employs fewer than 15 employees on
    any given day in that year.

    Page 13 GAO-05-54 Workforce Investment Act

    o  negotiating with recipients to secure voluntary compliance when
    noncompliance is found.

    Moreover, both the Governor and the recipient of WIA financial assistance
    are liable for all violations of Section 188 unless the Governor has,
    among other things, established, signed, and adhered to an MOA. 10 The MOA
    must be in writing and describe how the state programs and recipients of
    WIA financial assistance have satisfied the requirements of certain
    regulatory provisions, including those regarding people with disabilities.

    In addition, the Director of Labor's CRC has oversight responsibilities
    under the Section 188 regulations, which include:

         o conducting compliance reviews,
         o reviewing the activities of a governor, including the adequacy of the
           MOA, and
         o investigating and resolving complaints alleging violations of Section
           188.

    As part of its oversight responsibility, CRC, with assistance from ETA and
    ODEP, issued a compliance checklist on July 25, 2003, to ensure
    nondiscrimination and equal opportunity to persons with disabilities
    participating in WIA programs and activities. This checklist, officially
    known as the WIA Section 188 Disability Checklist, 11 identifies the
    regulations implementing Section 188 of WIA, including portions of the
    regulations implementing Section 504 of the Rehabilitation Act, and covers
    requirements applicable to local area grant recipients regarding the
    operation of their programs and activities. The checklist is based on the
    elements required by the MOA and includes lists of questions for each
    element of the MOA. For some of the elements, the questions are followed
    by examples of concrete actions that can be taken to ensure compliance
    with Section 188 requirements. The appendix to the Checklist also

    In order to be exempt from liability for Section 188 violations, the
    governor must also enter into a written contract with the recipient
    outlining the recipient's obligations under Section 188, act with due
    diligence to monitor the recipient's compliance with those provisions, and
    take prompt and appropriate corrective action to affect compliance.

    11The WIA Section 188 Checklist is located at
    http://www.dol.gov/oasam/programs/crc/section188.htm.

    Page 14 GAO-05-54 Workforce Investment Act

      Labor, Local Areas, and One-Stops Have Made Various Efforts and Degrees of
      Progress in Facilitating Access

    includes additional examples of policies, procedures, and other steps that local
         area grant recipients can take to ensure compliance with Section 188.

    Labor has awarded grants to facilitate comprehensive access to employment
    and training programs for persons with disabilities, and local areas and
    one-stop centers have also made numerous efforts, as well as various
    degrees of progress, in facilitating comprehensive access to their
    programs and services. Specifically, ETA has awarded over 100 grants to
    states and local entities for disability-related activities, such as
    enhancing comprehensive access to the one-stops. States and local areas
    have used these grants for a range of efforts, including assessing
    one-stop architectural accessibility, acquiring assistive technology
    devices, and increasing staff capacity to provide services to persons with
    disabilities.

        Federal Grants Have Provided Funding to Facilitate One-Stop Accessibility

    Between 2000 and 2004, ETA awarded state and local entities a total of
    approximately $65 million in competitive Work Incentive Grants in order to
    enhance one-stops' capacity to provide programs and services to persons
    with disabilities, which included improving one-stop accessibility. ETA
    awarded 113 grants in four rounds between 2000 and 2004. (See table 2.)

    Table 2: Work Incentive Grants: 2000, 2002, 2003, and 2004
                          Total
    Work Incentive    number Total amount of
                             of
    Grants            grants grants        States in which grants were
                        awarded awardeda      awardedb
    First round                            Alaska, California, Florida,
    (2000)                23   $20 million Illinois, Indiana, Iowa, Louisiana,
                                              Maine,
                                              Maryland, Massachusetts, Michigan,
                                              Missouri, Montana, New
                                              Hampshire, New Mexico, Ohio,
                                              Oregon, Pennsylvania, Rhode
                                              Island, Tennessee, Texas, Vermont,
                                              Washington
    Second round (2002)     23 $20 million California, Colorado, Connecticut,
                                              Florida, Hawaii, Illinois, Indiana,
                                              Kansas, Kentucky, Massachusetts,
                                              Minnesota, Missouri, New York,
                                              North Carolina, Oklahoma, Oregon,
                                              South Dakota, Tennessee,
                                              Texas, Virginia, Washington, West
                                              Virginia, Wisconsin
    Third round (2003)      42 $17 million Arizona, Arkansas, California, DC,
                                              Florida, Georgia, Hawaii, Illinois,
                                              Indiana, Michigan, Minnesota,
                                              Missouri, Nebraska, New Jersey,
                                              New Mexico, New York, North
                                              Carolina, Oklahoma, Oregon,
                                              Pennsylvania, Tennessee, Texas,
                                              Utah, Washington, West Virginia
    Fourth round (2004)      25 $8 million Alabama, Arkansas, California,
                                              Connecticut, Florida, Indiana,
                                              Kentucky, Maine, Michigan,
                                              Missouri, Montana, New Jersey, New
                                              York, North Carolina, Ohio,
                                              Tennessee, Texas, Virginia,
                                              Washington
    Total                113c $65 million

    Source: GAO analysis of Labor's Work Incentive Grant information.

    aThe Work Incentive Grants are funded through Labor's annual
    appropriation.

    b

    Grants could either be statewide in scope, meaning that they covered all
    local areas throughout the state, or local, meaning that they covered a
    designated region within a state (such as a specific local area). Although
    we are classifying grants by their state affiliation, this does not
    necessarily indicate that all local areas throughout the state benefited
    from the funds.

    cIn the first and second rounds, only one grant was awarded within each
    state that received a grant. In the third and fourth rounds, more than one
    grant was awarded within some states.

    On the basis of its experience administering the first two rounds of
    grants, ETA has targeted its specific grant objectives-and, therefore, its
    resources-to meet the emerging needs that states, local areas, and
    onestops have identified in providing programs and services to persons
    with disabilities. ETA's objectives for the early rounds of grants were
    relatively broad, and as a result, grantees were permitted to use the
    funds to undertake a range of activities, including:

         o assessing one-stops' architectural accessibility;
         o acquiring assistive technology devices;
         o conducting outreach to the disability community;
         o linking and coordinating with community disability-related agencies,
           such as community mental health agencies and independent living
           centers;
         o training existing one-stop staff on disability issues; and
         o making available staff who have the experience, knowledge, and skills
           necessary to address a broad range of disability-related issues.

    By the third round of grants, in 2003, ETA had begun to focus its
    priorities more narrowly-though not exclusively-on increasing the capacity
    of one-stop staff to provide services to persons with disabilities.
    According to the third round grant notice, previous grantees had found
    that building staff capacity was successful in improving overall service
    delivery in their one-stops. ETA officials said that although they believe
    that building staff capacity will enhance one-stops' progress toward
    making their services available to persons with disabilities, they
    recognize that some one-stops may also still need to address other issues,
    such as meeting the architectural access requirements. In addition to
    targeting their grant objectives, ETA officials said they plan to change
    the process by which they award grants. ETA used a competitive process to
    award all four rounds of grants, and as a result, according to ETA
    officials, some states or local areas that needed grants may not have
    received them. 12 ETA officials said they plan to use a different process
    in the future, which would allow them to target funding toward specific
    areas, such as states that did not receive grants in the first four rounds
    and/or states where they would like to intensify current grant activities.

    ETA, in conjunction with the Social Security Administration (SSA), which
    administers employment support programs for its disability beneficiaries,
    has provided approximately $24 million to fund a demonstration project
    focused on the establishment and training of one-stop Disability Program
    Navigators. 13 The Navigators' role is to address the needs of persons
    with disabilities seeking to use the one-stop system. Since July 2003,
    Navigator

    12

    Through this competitive process, an ETA technical review panel chose
    grantees by evaluating their applications against specified criteria (such
    as a statement of need). ETA officials explained that some applicants,
    such as those who were less adept at writing applications that met
    technical review standards, may not have received grants even though they
    needed them.

    13

    Of the $24 million in funds, Labor contributed approximately $15 million
    and SSA contributed $9 million.

        Local Areas and One-Stops Have Made Efforts to Facilitate Access to the
        One-Stops' Services, but Progress Has Varied

    grants have been awarded in a total of 17 states. 14 At the time of our
    review, this initiative had led to 221 Disability Program Navigators
    working in or with one-stops in those states. As designed by ETA and SSA,
    in collaboration with ODEP, Navigators are to provide expertise and serve
    as a resource to one-stops as well as persons with disabilities. ETA and
    SSA expected that Navigators would, in part, carry out many of the same
    types of accessibility-related activities that were funded under the
    initial Work Incentive Grants. The third and fourth rounds of the Work
    Incentive Grants have led to the hiring of staff who can perform functions
    similar to those of a Navigator. At the time of our review, 122
    Navigator-like staff had been established through the Work Incentive
    Grants. Eleven of the sites we visited had either Disability Program
    Navigators or Work Incentive Grant Navigators. Some of the Navigators we
    interviewed told us they had the following job responsibilities:

         o providing disability-related staff training;
         o helping staff locate resources for specific persons with disabilities,
           such as accommodations or services in the community;
         o developing relationships with disability-related service providers,
           such as VR and other community agencies; and
         o helping to ensure the accessibility of the one-stop, such as by
           conducting accessibility assessments or developing accessibility
           plans.

    During our site visits, we found that local areas and one-stop centers had
    made various efforts and degrees of progress in facilitating comprehensive
    access to the one-stops' programs and services. Specifically, we found the
    following:

    Architectural access. Our site visits showed that most local area and
    one-stop officials were working to implement architectural access
    standards, which are required by the WIA Section 188 regulations. Nearly
    all of the sites we visited had undergone at least one architectural

    14

    In July 2003, ETA and SSA's Office of Program Development and Research
    awarded Navigator grants to 14 states: Arizona, California, Colorado,
    Delaware, Florida, Illinois, Iowa, Maryland, Massachusetts, New York,
    Oklahoma, South Carolina, Vermont, and Wisconsin. ETA and SSA have since
    awarded Navigator grants to Mississippi, New Mexico, and Oregon. All 17 of
    these states were chosen for this effort because SSA has employment
    support initiatives in these locations.

    Page 18 GAO-05-54 Workforce Investment Act

    accessibility assessment within the last few years, and the assessments
    were typically conducted by VR or other disability-related agencies. Our
    review of these assessments showed that there were often considerable
    differences in the degree of architectural access that the locations had
    achieved. For example, some of the sites had either no or few problems
    with regard to architectural access. Other locations had a number of
    access-related problems, including those related to parking, ramps, and
    doors, as well as restrooms and signage. Some officials at these locations
    told us they had made at least some changes to improve architectural
    access. For example, some changes included:

         o adding or changing accessible parking spaces to meet requirements;
         o installing signage or changing existing signage to meet requirements;
         o building a new exterior ramp because the existing one did not meet
           architectural access requirements; and
         o installing electric door openers. 15

    Auxiliary aids and services. Many of the one-stops we visited had acquired
    auxiliary aids and services, such as assistive technology and materials in
    alternate formats, which the WIA Section 188 regulations require that
    one-stops provide to persons with disabilities when necessary. Auxiliary
    aids and services include a range of devices, equipment, and services that
    provide effective communication for persons with various types of
    impairments. According to ETA, the auxiliary aids and services requirement
    covers any method of communication, including verbal, written,
    computer-based, or telephone communications. Assistive technology refers
    to products or equipment that can be used to help people with disabilities
    perform their major life functions. Some types of assistive technology can
    be used to make existing information technology, including computers and
    telephones, available to persons with disabilities. Alternate formats can,
    for instance, make written or visual materials available to persons with
    visual impairments or make oral information available to persons with
    hearing impairments. Table 3 describes selected

    Electric door openers are not required by either the Uniform Federal
    Accessibility Standards (UFAS) or the Americans with Disabilities Act
    Accessibility Guidelines for Buildings and Facilities (ADAAG). However,
    officials from some sites said that their lack of electric doors was an
    accessibility concern.

    Page 19 GAO-05-54 Workforce Investment Act

    types of auxiliary aids and services that were available in some of the
    onestops we visited.

    Table 3: Selected Types of Auxiliary Aids and Services
                                                Examples of impairments for which
    Type                      Purpose                    the aid or service
                                                            may be beneficial
    Screen reading software   Software programs that     Visual impairments
                                 present text as speech
                                                            Cognitive impairments
                                     Software that can
    Screen magnification software increase the size of   Visual impairments
                                     characters on a
                         computer screen
    Closed-circuit              Electronically magnifies
    television/video            printed text and         Visual impairments
                                   displays it on a
    magnifier                   monitor
                                   Software programs that
    Speech recognition software allow users to give      Visual impairments
                                   commands and
                                   enter information using  Mobility impairments
                                   speech rather than a
                                   mouse or
                                   keyboard                 Cognitive impairments
                                   Increases character size
    Large-screen computer       in proportion to         Visual impairments
                                   computer monitor
    monitors                    dimensions
                                   An alternative to a
    Trackball mouse             standard mouse, this     Mobility impairments
                                   mouse has
         movable balls on top of a base that can be used to
                                                       move
                       the cursor on screen
    Alternative keyboards  Those with larger or smaller  Mobility impairments
                              than standard keys or
    keyboards, alternative key configurations, keyboards
                                                        for
                  use with one hand, and others
                                  Device that lets people
    TTY (text telephone)/TDD   with hearing or speech    Hearing impairments
                                  impairments
    (telecommunications device use the telephone to      Speech impairments
                                  communicate, by allowing
                                  them to
    for the deaf)              type messages back and
                                  forth to one another
                                  instead of
                      talking and listening
    Other assistive          Devices that amplify sound
    listening                in specific listening       Hearing impairments
                                situations
    devices                  (e.g., watching television, Cognitive impairments
                                using the telephone), while
                                                       also
             reducing the effects of background noise
                                 Presenting print or visual
    Alternate formats      materials in Braille or large Visual impairments
                                                     print,
                           on audiotape, or on compact disk Cognitive impairments
                           Presenting spoken information in
                           writing                          Hearing impairments
                                                            Cognitive impairments

    Source: GAO summary of information collected through site visits and from
    access guides.

    At the time of our site visits, a few one-stops had either recently
    installed assistive technology for the first time or were still in the
    process of acquiring it. However, other sites had assistive technology,
    and some or all of the staff had already received training in how to use
    it. Some of these sites offered a range of devices, which could assist
    many types of impairments. Given the wide variety of devices available,
    some local areas and one-stops targeted their resources, at least
    initially, toward items that might be used frequently. For example, one
    local area-working with an agency that had assistive technology
    expertise-collected data on the types of impairments that were most
    prevalent among potential customers and then used these data to determine
    which devices to purchase first. In addition, a couple of officials said
    that their one-stops had some materials, such as basic orientation
    materials, routinely available in Braille or largeprint formats. Some
    officials told us that they did not have any of their materials routinely
    available in alternate formats, although they would provide these to
    customers upon request. In some cases, officials said that they could
    rapidly provide customers with certain types of alternate formats, such as
    Braille, large print, computer diskette, or compact disk, through the use
    of their assistive technology or computers.

    Reasonable accommodations. Some officials and staff we interviewed said
    they try to make reasonable accommodations for persons with disabilities.
    Reasonable accommodations, which are required by the WIA Section 188
    regulations, enable persons with disabilities to receive aid, benefits,
    services, or training equal to that provided to persons without
    disabilities. For example, a number of officials and staff mentioned that
    although they did not have a qualified American Sign Language interpreter
    on-site at their one-stops, they have obtained an interpreter upon a
    customer's request. 16 However, during our site visits, we also found that
    local area and one-stops' policies and procedures for providing reasonable
    accommodations varied. For example, officials from a few local areas and
    one-stops said they referred to their state workforce agency's or their
    local government's policies for guidance on this issue. A few officials
    said that they had developed their own local accommodation policies or
    procedures, or planned to do so. For example, one local area developed
    written policies and procedures that provided information on how customers
    should request an accommodation, which staff could assist in providing a
    reasonable accommodation, and which staff were responsible for determining
    if the one-stop is able to provide the accommodation. In addition, some
    officials told us that when they have received accommodation requests,
    they have not maintained records on the types of accommodations requested
    or whether the one-stop provided these accommodations. However, in at
    least one of the local areas we visited,

    A reasonable accommodation may require making specific structural or other
    modifications, including the provision of auxiliary aids and services such
    as sign language interpreters, telephone amplifiers, or alternate formats,
    to meet the specific needs of a particular customer with a disability.
    Accommodations are generally provided only after an individual with a
    disability requests it, as opposed to being available up front.

    Page 21 GAO-05-54 Workforce Investment Act

    the local equal opportunity officer-who addressed all accommodation
    requests-said that he maintained records on this information.

    Integrated settings. During our site visits, we found variation in
    viewpoints regarding the practice of automatically referring persons with
    disabilities to VR for services. 17 Even though agencies such as VR could
    provide services to persons with disabilities, the WIA Section 188
    regulations require that one-stops allow persons with disabilities the
    opportunity to receive services in the most integrated setting appropriate
    to meet their needs. An integrated setting is one that enables persons
    with disabilities to interact with persons without disabilities. Although
    a referral to VR may be appropriate for some individuals, automatically
    referring all persons with disabilities to VR does not allow for the
    opportunity to receive services along with persons without disabilities.
    Moreover, an automatic referral to VR does not provide customers with an
    individualized assessment of their abilities and needs.

    Some local area and one-stop officials we interviewed acknowledged that
    automatic referrals to VR did occur in the past. However, a number of
    officials and staff understood that this practice is not appropriate, or
    said that it is not currently occurring in their one-stops. Some of these
    officials and staff said that services for persons with disabilities are
    determined on a case-by-case basis and that unless these individuals want
    or indicate that they need VR services, they are not referred to VR. Some
    WIA officials, as well as a few VR officials and others who have provided
    staff training on disability issues, explained that one-stop staff have
    been trained not to automatically refer persons with disabilities to VR.
    For example, staff were trained not to stereotype persons with
    disabilities or assume that they need VR services, or were trained to
    provide these customers with a choice regarding which services they use.

    However, during our site visits, officials in two local areas told us that
    they currently found it preferable or necessary to automatically refer
    persons with disabilities to VR. Officials from one local area stated that
    while a disability-related agency advised them that one-stop staff should
    not be automatically referring persons with disabilities to VR, they took
    exception to this guidance. The local area officials explained that it
    would

    Individuals with disabilities who are eligible for VR services are those
    persons who have a physical or mental impairment that, for an such
    individual, constitutes or results in a substantial impediment to
    employment, and who can benefit in terms of an employment outcome from
    vocational rehabilitation services.

    Page 22 GAO-05-54 Workforce Investment Act

    be irresponsible of them not to fully utilize the expertise of the only
    mandatory disability partner in the WIA system. Officials from another
    local area said that although their long-term goal is to train one-stop
    staff to work directly with persons with disabilities, they believe that
    their onestop staff are currently referring these customers to VR.
    Additionally, some WIA, VR, and disability-related agency officials also
    expressed concerns that trying to meet performance standards could provide
    an incentive for one-stops to automatically refer persons with
    disabilities to VR, only serve those with the least severe disabilities,
    or not serve them at all. Some officials explained that it is sometimes
    more difficult for persons with disabilities, particularly those with more
    severe disabilities, to find and retain jobs, and that it is often more
    costly for the one-stop to serve these individuals.

    Marketing and outreach. Some officials and staff we interviewed cited a
    variety of reasons why marketing the one-stops' services and conducting
    outreach to persons with disabilities, which are activities required by
    the WIA Section 188 regulations, may be important. One of the reasons
    cited was that many individuals in the community, including those with
    disabilities, were still not aware of the types of programs and services
    that one-stops offer. For example, a one-stop official said that one-stops
    are often thought of as an employment service, without recognition that
    they can offer participants education, referrals to disability-related
    agencies for services, and other assistance. Some WIA officials and
    disability-related agency representatives also said that even when the
    disability community knows what the one-stops offer, the one-stops often
    have to overcome the belief that one-stops do not want to, or are not
    capable of, providing services to persons with disabilities. For example,
    the disability community may believe that the one-stops do not have
    assistive technology or provide other assistance to persons with
    disabilities. Additionally, some officials also stated that they believe
    that persons with disabilities are still more likely to seek services from
    disability-related organizations than from one-stops.

    Some of the officials from local areas and one-stops that had engaged in
    marketing and outreach efforts said they had used one or more
    community-based disability organizations in their efforts. For example,
    local areas or one-stops sometimes approached independent living centers,
    agencies that serve individuals with specific types of disabilities, or
    other organizations to inform them about the one-stops' services and their
    accessible technology. Some officials also said they used brochures,
    television or radio ads, billboards, or other means to market their
    services to persons with disabilities. Other local area and one-stop
    officials told us about the specialized techniques they used, such as
    holding a yearly job fair for persons with disabilities, which provides
    attendees with information about one-stop services.

    Officials in a few local areas and one-stops, however, stated that they
    were hesitant to market their services to persons with disabilities. For
    example, one local area official was not confident about the ability of
    some one-stop staff to handle disability issues and, as a result, did not
    want to market what the one-stops in the area could not provide. An
    official in another local area expressed a similar viewpoint with regard
    to the lack of marketing around an assistive technology device that had
    not been used. The official stated that the local area had not advertised
    the device because he did not believe the one-stops in that area were
    fully capable of providing services to persons with disabilities.

    Staff training. Although the WIA Section 188 regulations do not
    specifically require that one-stop staff, other than the equal opportunity
    officer and his or her staff, receive training on disability, the WIA
    Section 188 Checklist includes training as one example of how one-stops
    can ensure compliance with WIA's comprehensive access requirements.
    Onestop staff in the majority of the local areas we visited had received
    some disability-related information and training, but the range of topics
    covered varied across sites. For example, officials in at least one local
    area told us that they were still focusing on providing staff with
    disability awareness training, while officials, staff, and staff training
    providers in other locations described a wider range of training topics,
    such as:

         o disability awareness or sensitivity training; 18
         o types of services that VR provides, and the agency's eligibility rules
           and criteria;
         o types of disability-related agencies in the community, as well as who
           they serve, the types of services they offer, and their contact
           information;

    Disability awareness or sensitivity training teaches one-stop staff, for
    example, to use people-first language-such as "an individual with a
    disability" as opposed to "the disabled." It may also include education on
    how to interact with persons with disabilities, such as asking if an
    individual needs assistance first rather than automatically providing it
    or speaking directly to a person who is deaf instead of speaking to the
    person's sign language interpreter.

    Page 24 GAO-05-54 Workforce Investment Act

         o how to identify certain disabilities, including hidden disabilities
           such as mental illness or learning disabilities; and
         o WIA Section 188 training.

    We also found that a few local areas and one-stops created comprehensive
    training programs or targeted their training to identified staff needs.
    For example, one local area created an extensive disability-training
    program that provides online and in-class training on a range of relevant
    disabilityrelated issues and discusses these issues in the context of
    particular disabilities. This training program has been made available on
    a statewide basis. Also, in one state, staff at the three one-stops we
    visited had undergone, or were scheduled to undergo, an assessment of
    their training needs. These assessments were then going to be used to
    develop training plans for each of these one-stops.

    Some officials and staff stated that the available disability-related
    staff training was beneficial and provided positive outcomes. For example,
    some officials and staff said that the available training made staff more
    comfortable interacting with, and providing services to, persons with
    disabilities and helped them learn about the range of disability-related
    services that VR and other agencies in the community offer. However, other
    officials and staff expressed some concerns about the available training.
    For example, a few of these officials and staff said that they would like
    training on specific disability-related topics to be available, and in at
    least one case, local area and one-stop officials had concerns about how
    well their limited training prepared staff for providing services to
    persons with disabilities. Additionally, some of the officials, staff, and
    staff training providers we interviewed said that their training efforts
    were affected by high staff turnover and the prospect of staff forgetting
    the information learned in training if it is not used very often. Some
    officials, staff, and staff training providers said that offering ongoing
    training was important for these reasons or that they would like ongoing
    training to be available in their one-stops.

      One-Stops and Disability Agencies Have Established Various Relationships to
      Serve Persons with Disabilities

    One-stops, VR, and other disability-related agencies in the community have
    formed various relationships to provide services to persons with
    disabilities. From our site visits, we found that the structure of the
    onestops' relationships with VR varied, particularly in terms of whether
    co-location was occurring. While most of the one-stops we visited had VR
    staff on-site at least part of the time, four of the sites we visited had
    no on-site VR staff. Table 4 shows the co-location status of VR staff at
    the one-stops we visited.

          Table 4: Co-location Status of VR Staff in the One-Stops We Visited

                     Co-location status of VR staff Number of sites

    One or more VR staff on-site on a full-time basis

    One or more VR staff on-site on a part-time basis

    No VR staff on-site

    Source: GAO site visits.

    Officials from the sites at which full- or part-time co-location of VR
    staff was taking place said that co-location was beneficial for a variety
    of reasons. For example, some WIA and VR officials said that co-location
    itself helped the one-stop staff provide faster and less fragmented
    services to persons with disabilities because, when the one-stop staff
    made referrals to VR, they did not have to send customers off-site. A few
    officials also stated that co-location facilitated information sharing and
    helped build relationships between the staff in the two agencies. The
    reasons for VR staff not being on-site also varied, and included a lack of
    space in the one-stop, the inability of VR to break its lease at an
    existing local office, and lack of an interface between the one-stops' and
    VR's computer systems.

    The one-stops we visited also varied in terms of the extent to which they
    formed relationships with disability-related service providers other than
    VR. Although VR has extensive expertise in providing services to persons
    with disabilities, other disability agencies in the community also have
    expertise and resources that can benefit one-stops. At the time of our
    site visits, a few local areas and one-stops were relying primarily on VR
    and had not formed working relationships with any other disability
    agencies. However, other local areas and one-stops we visited had formed
    relationships with one or more disability-related organizations in the
    community, such as independent living centers, mental health agencies, and
    cognitive/developmental disability agencies. 19 In at least one instance,
    a local area formed relationships with agencies that focus on particular
    impairments. This local area conducted a needs analysis and found that
    relationships with organizations that provide services to persons with
    psychiatric impairments, learning disabilities, and substance abuse issues
    were lacking. As a result, the local area conducted outreach to these
    types of organizations in order to initiate relationships with them.

    Officials from local areas and their one-stops, as well as those from VR
    and community disability agencies, cited a range of benefits to being able
    to refer their customers to one another for services, when it was
    appropriate to do so. For example, some WIA and VR officials said the
    one-stop's relationship with VR allowed the two agencies to combine their
    resources to maximize the services they can provide to their customers.
    For example, for co-enrolled customers, one agency might pay for school
    tuition while another pays for books. Some local area and one-stop
    officials also said that referring customers to VR and other community
    disability agencies is beneficial because those agencies have the ability
    and funding to provide certain services that the one-stops cannot. In
    addition, officials in some local areas and one-stops said that VR and
    other community agencies' willingness to conduct staff training, provide
    onestop accessibility assessments, or participate in one-stop access
    committees was beneficial.

    VR and community disability agencies also cited a number of benefits to
    referring their customers to the one-stops, including access to the
    onestops' career resource centers' computers and telephones, their
    workshop or training classes (such as those for computer skills, interview
    skills, and resume-writing), and a range of job listings and employer
    connections broader than their own. VR officials also cited other
    benefits. For example, when a VR customer is faced with delayed services
    because VR is waiting for documents substantiating the customer's
    disability, the one-stops can provide other services in the interim.
    Additionally, VR officials told us they find it useful to refer
    individuals who did not qualify for services through

    These community-based disability organizations typically did not co-locate
    their staff at the one-stops on either a full-time or a part-time basis.
    However, there were some exceptions-such as, for example, in cases in
    which the disability-related agencies were the sole or co-operators of a
    one-stop.

    Page 27 GAO-05-54 Workforce Investment Act

      Labor Has Taken Actions to Ensure That One-Stops Comply with Access
      Requirements, but These Efforts May Not Be Sufficient

    VR, whether because of limited funding 20 or other reason, to the one-stop
    for services.

    Labor has taken several actions to ensure that persons with disabilities
    have comprehensive access to one-stops, including training, monitoring,
    and enforcement activities, but these efforts may not be sufficient. For
    example, Labor has not only funded grants, it has also provided training
    in ways to facilitate comprehensive accessibility in the one-stop centers.
    Specifically, within Labor, ETA and ODEP, along with SSA, provided
    Disability Program Navigator training in November 2003 in which successful
    approaches to ensuring comprehensive access to one-stops were discussed.
    Additional Disability Program Navigator training was provided in November
    2004. Further, CRC, with assistance from ETA and ODEP has provided written
    guidance and assistance to one-stops on accommodations and other ways to
    improve comprehensive access for persons with disabilities. Also within
    Labor, CRC conducts national equal opportunity training annually. Its
    August 2004 training included topics such as new EO officer orientation,
    implementing an MOA, ensuring compliance with WIA Section 188, testing and
    assessment tools for improving services to persons with disabilities, and
    train-the-trainer EO training.

    In addition to providing training, CRC is the entity responsible for
    interpreting, monitoring, and enforcing WIA Section 188 regulations
    regarding programs receiving financial assistance from Labor, including
    the applicable comprehensive access and administrative regulatory
    requirements for one-stop centers. One key method Labor uses to ensure
    compliance with these regulations has been to require that each state's
    governor establish and sign an MOA, which describes and contains
    supporting documentation of the policies, procedures, and systems that
    each state has established to ensure compliance. By signing the MOA, and
    submitting it to CRC, the governor agrees to adhere to its provisions. CRC
    provides guidance on preparing the MOA, reviews the adequacy of each state
    MOA submitted, and approves those MOAs that meet its standards. Currently,
    all governors have submitted MOAs that have been approved by CRC. After
    initial approval, states are to notify CRC of any updates to their

    20

    In states where VR funding is not sufficient to serve all eligible
    clients, there may be an order of selection in place, whereby VR is able
    to accept only those individuals with the most significant disabilities
    who could benefit from VR services. Of the states we visited, only one was
    not under an order of selection for the general disability population.

    Page 28 GAO-05-54 Workforce Investment Act

    MOAs, and every 2 years Labor requires states to review them and the
    manner in which they have been implemented, and determine whether their
    MOAs continue to be effective in ensuring compliance with the requirements
    of WIA Section 188 and its implementing regulations.

    In addition, CRC monitors states' compliance with the nondiscrimination,
    comprehensive access, and administrative regulatory requirements by
    conducting on-site technical assistance compliance reviews at selected
    locations. To facilitate the review process, CRC conducts a 2-to 3-day
    training session for state, local workforce investment area, and one-stop
    center staff. 21 In 2003, CRC completed its first phase of on-site
    training, technical assistance, and compliance reviews in two large
    metropolitan areas in two states, Miami/Dade County, Florida, and New
    York, New York. According to Labor's 2003 Annual Report, CRC focuses its
    reviews on large metropolitan areas so as to maximize the use of its
    resources. The annual report notes that the large labor markets in these
    areas provide the opportunity for gaining a representative picture of the
    degree of compliance with nondiscrimination and equal opportunity laws and
    regulations.

    In both metropolitan areas it reviewed, CRC identified instances of
    noncompliance, including the existence of barriers limiting services to
    persons with disabilities. At one of the two metropolitan areas, CRC found
    significant differences between the disability-related requirements in WIA
    Section 188 and its implementing regulations and the policies, procedures,
    and systems that were actually being used. For example, CRC found that the
    local area had developed a service delivery system in which customers with
    disabilities were routinely being served by programs or activities that
    were separate from those used to serve customers without disabilities.
    Officials at the local area told CRC such a service delivery system had
    developed in part because there was a general sentiment among
    disabilityrelated service providers that many of their customers did not
    feel comfortable in the one-stops. The WIA Section 188 regulations,
    however, require that services to qualified persons with disabilities be
    provided in the most integrated settings appropriate to the needs of those
    customers. Therefore, as noted in CRC's review, a one-stop center
    generally should not refer customers with disabilities to a separate
    program or activity until

    In addition to CRC staff, presenters at the sessions included staff from
    ETA and ODEP, as well as representatives of the United States Access
    Board, and the Job Accommodation Network.

    Page 29 GAO-05-54 Workforce Investment Act

    after it has conducted an individualized assessment of a customer's needs,
    and determined that the channels used to serve customers without
    disabilities cannot provide equally effective aid, benefits, services, or
    training to persons with disabilities. In addition, the ultimate decision
    whether to accept the referral to a separate program or activity must be
    left up to the customer with a disability. If the customer declines to
    accept the referral, the one-stop must serve the customer with a
    disability through the same programs or activities used to serve all other
    customers.

    In addition, CRC found that the EO officer at the local area in that
    metropolitan area had not been provided with sufficient staff, other
    resources, or adequate support from top management to carry out his
    duties. As a result, staff at the local workforce investment area and
    one-stops had little understanding of their disability-related or other
    obligations under WIA Section 188 regulations.

    At the other metropolitan area reviewed, CRC found that some of the
    policies, procedures, and systems in the state's approved MOA had not been
    fully implemented. For instance, the local workforce investment area had
    developed an intake eligibility form for use by the one-stops that
    included questions concerning whether or not the customer had a disability
    that was or was not a substantial barrier to employment. Frontline staff
    at the one-stop centers told CRC that all customers were welcome to use
    self-service and core services. However, CRC found that customers who
    indicated on the intake form that they had a disability could not receive
    intensive or training services unless they provided the one-stop with
    documentation to support their disability, even when disability was not an
    eligibility criterion to receive such services. CRC found that the use of
    the intake form, combined with the requirement that customers provide
    documentation of their disability, unnecessarily screened out people with
    disabilities from receiving intensive and training services, even though
    Labor's WIA Section 188 regulations require that the one-stops must not
    deny any qualified person with a disability the opportunity to participate
    in, or benefit from, a WIA-funded program or activity because of that
    person's disability. On the basis of its findings, CRC required the state
    entities responsible for WIA in which the two metropolitan areas were
    located to provide it with written responses of the corrective actions
    they planned to make.

    In addition, in May 2004, the CRC Director requested that all states
    complete, for themselves and their largest local area, a self-assessment
    tool to assess compliance with the equal opportunity and nondiscrimination
    laws and regulations. The self-assessment tool, which

      Information on Employment Outcomes Is Limited

    provides a structured approach for monitoring compliance, was adapted from
    the WIA Section 188 Disability Checklist. For each state and its largest
    local workforce investment area, the self-assessment tool asks whether or
    not each measure of compliance has been met. For all unmet measures, the
    self-assessment tool asks for a written explanation of how and when the
    measure will be met. At the time of our review, CRC was in the process of
    developing a plan to analyze the qualitative responses they would receive
    from the states. CRC anticipates using the information provided by these
    self-assessments and from its on-site reviews to identify exemplary
    practices as well as areas needing improvement.

    In addition to the two on-site reviews CRC conducted in 2003, CRC is in
    the process of conducting two additional reviews in two large metropolitan
    areas in two other states, which it plans to complete during fiscal year
    2005. To date the monitoring and enforcement efforts that have been or are
    being conducted account for less than 2 percent of the total number of
    local areas and one-stops nationwide. Moreover, the CRC Director said that
    she had not yet determined whether CRC would conduct additional on-site
    reviews. Limited staff and competing work priorities may hinder CRC's
    ability to conduct additional reviews. The Director noted that CRC has
    experienced an erosion in the number of staff since 1998, and she did not
    foresee any change to this trend in the future. The 44 professional and
    administrative staff that CRC currently has are responsible for not only
    all issues involving discrimination in one-stops and other Labor-funded
    programs, but also for all discrimination issues involving the more than
    17,000 employees at Labor. Moreover, the Director explained that these
    staff are also responsible for addressing other workload priorities, such
    as issues to improve access to programs and activities for persons who are
    limited in their English proficiency.

    Information about the employment outcomes of persons with disabilities is
    limited by the extent to which disability data are collected and the
    overall methods used for collecting data for WIA's performance measures.
    The three WIA-funded programs-Adult, Dislocated Worker, and Youth- have
    performance measures established under WIA that states must track and
    report in order to demonstrate the effectiveness of the programs. These
    performance measures gauge program results in such areas as job placement,
    employment retention, earnings changes, and skill attainment. In addition
    to providing information about all participants in the three WIA-funded
    programs, Labor also publishes outcome information about certain
    subpopulations, including veterans, older individuals, and persons with
    disabilities.

    The information Labor publishes on the employment outcomes of persons with
    disabilities, however, is limited for several reasons. One reason is that
    the information is limited to the subpopulation of persons with
    disabilities who disclose their disability status, and therefore the
    employment outcomes may be misleading for the total population of persons
    with disabilities receiving services through WIA. The WIA Section 188
    regulations require one-stops to collect, maintain, and report job
    seekers' demographic data-including disability status-to ensure that
    discrimination is not occurring. Labor has issued guidance stating that
    one-stops must inquire about disability status from job seekers upon
    registration for services. Such inquiries must be asked of all job
    seekers, but an individual's decision to disclose his or her disability
    status must be completely voluntary. Even though an individual declines to
    indicate his or her disability status, the one-stop must still provide
    services to the individual.

    Further, the collection of information on employment outcomes, including
    the information on persons with disabilities, is limited to those persons
    who are registered for WIA services. Current law does not require job
    seekers who receive services that are self-service and informational in
    nature to be included in the performance measures. Labor's guidance
    instructs states to register and report on adults and dislocated workers
    who receive core services that require significant staff assistance
    designed to help with job seeking or acquiring occupational skills, but
    states have flexibility in deciding what constitutes significant staff
    assistance. 22 We have previously reported that most of the one-stop
    customers who participate in self-directed services, and receive only
    limited staff assistance, are estimated to be the largest proportion of
    job seekers under WIA. 23 But since they are not registered for services,
    they are excluded from the employment outcome data published by Labor. In
    that report, we also noted that Labor said that it is developing a new
    reporting system that would enable states to report activity and outcomes
    for all WIA participants. According to Labor, tracking all one-stop job
    seekers will enable officials to obtain information about who is served,
    what services

    All youth who receive WIA-financially assisted services are required to be
    registered. 23 GAO-04-657.

    Page 32 GAO-05-54 Workforce Investment Act

                                      Conclusions

    are provided, which partner programs provided the services, and what
    outcomes are achieved. 24

    Finally, the performance measurement system developed under WIA may have a
    negative effect on the economic outcomes of some people with disabilities
    because the performance levels may provide a disincentive to serve certain
    clients, including those with disabilities. Under WIA, performance levels
    are tied to incentives and sanctions so that states can be financially
    rewarded if they meet them or penalized if they do not. As such, local
    areas may be reluctant to provide WIA-funded services to job seekers,
    including persons with disabilities, who may be less likely than others to
    find employment or experience an increase in earnings when they are placed
    in jobs. To address this issue, we recently recommended that the Secretary
    of Labor develop an adjustment model or other systematic method to account
    for different populations and local economic conditions when negotiating
    performance levels. 25 In commenting on our recommendation, Labor agreed
    with the importance of taking economic conditions and characteristics of
    the population into account when setting performance expectations and had
    commissioned a study of adjustment models that could better take these
    differences into account.

    The WIA one-stop system's ability to provide comprehensive access to its
    programs, services, and activities can affect whether, and how,
    individuals with disabilities participate in the American workforce.
    Although Labor has developed specific regulations requiring that people
    with disabilities have equal opportunity to participate in and benefit
    from the programs and services offered in the WIA one-stop system, its
    efforts to date may not be sufficient to ensure that result. Five years
    after Labor issued regulations implementing the nondiscrimination and
    equal opportunity provisions of WIA Section 188, the agency has yet to
    develop and implement a long-term plan for ensuring that the one-stop
    system complies with the comprehensive access requirements for persons
    with disabilities. Although CRC, ETA and ODEP have worked together on some
    comprehensive

    24

    In addition, on July 16, 2004, Labor published a notice in the Federal
    Register on a proposal to collect additional information on the types of
    impairments that one-stop customers have, including learning disabilities,
    visual, hearing, and speech impairments, and cognitive and psychological
    impairments. Labor believes that collecting information on impairment
    types will facilitate its ability to focus on, and evaluate its
    effectiveness in, servicing people with disabilities through the one-stop
    system.

    25GAO-04-657.

    access projects, they have not developed an overall plan to conduct the
    activities necessary to ensure comprehensive access to one-stops for all
    Americans.

    To improve comprehensive access for persons with disabilities to the one-

      Recommendation

    stop system, we recommend that Labor develop and implement a longterm plan
    for ensuring that the one-stop system complies with the comprehensive
    access requirements for people with disabilities. Moreover, in this era of
    constrained resources, Labor should utilize the expertise of CRC, ETA, and
    ODEP staff in developing such a plan.

                                    Agency Comments

    We provided a draft of this report to the Departments of Labor and
    Education for their review and comments. Education did not have comments
    on our report.

    Labor generally agreed with our recommendation and said that even more
    could be done to ensure comprehensive access within the one-stop system.
    Specifically, ETA has pledged to work with ODEP and CRC to develop and
    implement a long-term plan for addressing comprehensive access in the
    one-stop system. ETA also suggested that the development of such a
    long-term plan should include all of the participating agencies and
    programs. Moreover, ODEP stated that the comprehensive plan should also
    address nonspecialized disability supports and services, such as
    transportation.

    ODEP and CRC also provided us with some general comments on our report.
    ODEP noted that, in addition to the WIG and Navigator grants, Labor
    supports other efforts to facilitate the inclusion of people with
    disabilities in the one-stop system. Although our report focuses on those
    grants that are most directly related to facilitating comprehensive access
    in the one-stop system, we have added examples of some of the types of
    grants that ODEP has awarded to support employment-related initiatives for
    people with disabilities. In addition, CRC asked us to clarify our use of
    the term comprehensive access. CRC expressed some concern that we had
    included administrative requirements in the use of the term comprehensive
    access. CRC believed that administrative requirements should not be
    included as they are not specifically disability-related. We have modified
    the language in our report to clarify that the administrative requirements
    are not included in the term comprehensive access.

    ETA, ODEP, and CRC also provided us with technical comments and
    clarifications, which we have incorporated as appropriate. Copies of their
    comments appear in appendix I.

    We are sending copies of this report to the Secretary of Labor, the
    Secretary of Education, relevant congressional committees, and others who
    are interested. Copies will also be made available to others upon request.
    The report will be available on GAO's Web site at http://www.gao.gov.

    Please contact me on (202) 512-7215 if you or your staff have any
    questions about this report. Other major contributors to this report are
    listed in appendix II.

    Sigurd R. Nilsen

    Director, Education, Workforce and Income Security Issues

    Appendix I: Comments from the Department of Labor

                       Page 37 GAO-05-54 Workforce Investment Act

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    Appendix II: GAO Contacts and Staff Acknowledgments

    Carol Dawn Petersen, Assistant Director (202) 512-7215

      GAO Contacts

    Gretta L. Goodwin, Senior Economist (202) 512-7215

    William E. Hutchinson and Caterina Pisciotta made significant

      Staff

    contributions to all phases of this report. In addition, Jessica Botsford
    and Acknowledgments Richard Burkard provided legal assistance, and Amy
    Buck assisted in report development.

    Related GAO Products

    Workforce Investment Act: States and Local Areas Have Developed Strategies
    to Assess Performance, but Labor Could Do More to Help. GAO-04-657.
    Washington, D.C.: June 1, 2004.

    Workforce Investment Act: One-Stop Centers Implemented Strategies to
    Strengthen Services and Partnerships, but More Research and Information
    Sharing Is Needed . GAO-03-725. Washington, D.C.: June 18, 2003.

    Workforce Investment Act: Exemplary One-Stops Devised Strategies to
    Strengthen Services, but Challenges Remain for Reauthorization.
    GAO-03-884T. Washington, D.C.: June 18, 2003.

    Workforce Training: Employed Worker Programs Focus on Business Needs, but
    Revised Performance Measures Could Improve Access for Some Workers.
    GAO-03-353. Washington, D.C.: February 14, 2003.

    Older Workers: Employment Assistance Focuses on Subsidized Jobs and Job
    Search, but Revised Performance Measures Could Improve Access to Other
    Services . GAO-03-350. Washington, D.C.: January 24, 2003.

    Workforce Investment Act: States and Localities Increasingly Coordinate
    Services for TANF Clients, but Better Information Needed on Effective
    Approaches. GAO-02-696. Washington, D.C.: July 3, 2002.

    Workforce Investment Act: Improvements Needed in Performance Measures to
    Provide a More Accurate Picture of WIA's Effectiveness. GAO-02-275.
    Washington, D.C.: February 1, 2002.

    Voters with Disabilities: Access to Polling Places and Alternative Voting
    Methods. GAO-02-107. Washington, D.C.: October 15, 2001.

    Workforce Investment Act: Better Guidance Needed to Address Concerns over
    New Requirements . GAO-02-72. Washington, D.C.: October 4, 2001.

    Workforce Investment Act: New Requirements Create Need for More Guidance.
    GAO-02-94T. Washington, D.C.: October 4, 2001.

    (130307)

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