All The Law Allows: The 13 Considerations of WIOA

Adult Basic Skills Education has changed a lot over the years. Just in five years, we have seen regulations come and go about what we have to do for funding to keep our programs–our jobs–alive. When this post was written in 2018, adult education programs had to comply with the following guidelines known as the Thirteen Considerations of WIOA. These considerations are still in play today.

The original text is worded as such:

WIOA’s 13 Considerations

(1) The degree to which the eligible provider would be responsive to —

  • regional needs as identified in the local plan; and
  • serving individuals in the community who were identified in such plan as most in need of adult education and literacy activities, including individuals who have low levels of literacy skills; or who are English language learners;

(2)  the ability of the eligible provider to serve eligible individuals with disabilities, including eligible individuals with learning disabilities;

(3)  past effectiveness of the eligible provider in improving the literacy of eligible individuals, to meet State-adjusted performance levels, especially with respect to eligible individuals who have low levels of literacy;

(4)  the extent to which the eligible provider demonstrates alignment between proposed activities and services and the strategy and goals of the local plan, as well as the activities and services of the one-stop partners;

(5)  whether the eligible provider’s program—

  • is of sufficient intensity and quality, and based on the most rigorous research available so that participants achieve substantial learning gains; and

(B) uses instructional practices that include the essential components of reading instruction;

(6)   whether the eligible provider’s activities, including whether reading, writing, speaking, mathematics, and English language acquisition instruction delivered by the eligible provider, are based on the best practices derived from the most rigorous research available and appropriate, including scientifically valid research and effective educational practice;

(7)  whether the eligible provider’s activities effectively use technology services and delivery systems including distance;

(8)  whether the eligible provider’s activities provide learning in context, including through integrated education and training, so that an individual acquires the skills needed to transition to and complete postsecondary education and training programs, obtain and advance in employment leading to economic self-sufficiency, and to exercise the rights and responsibilities of citizenship;

(9)  whether the eligible provider’s activities are delivered by well-trained instructors, counselors, and administrators who meet any minimum qualifications established by the State, where applicable, and who have access to high quality development, including through electronic means;

(10)   whether the eligible provider’s activities coordinate with other available education, training, and social service resources in the community, such as by establishing strong links with elementary schools and secondary schools, postsecondary educational institutions, institutions of higher education, local workforce investment boards, one-stop centers, job training programs, and social service agencies, business, industry, labor organizations, community-based organizations, nonprofit organizations, and intermediaries, for the development of career pathways;

(11)  whether the eligible provider’s activities offer flexible schedules and coordination with Federal, State, and local support services (such as child care, mental health services, and career planning) that are necessary to enable individuals, including individuals with disabilities or other special needs, to attend and complete programs;

(12)  whether the eligible provider maintains a high-quality information management system that has the capacity to report measurable participant outcomes and to monitor program performance; and

(13)  whether the local areas in which the eligible provider is located have a demonstrated need for additional English language acquisition programs and civics education programs.


These considerations are important to understand, and we can benefit from a translation into plain English. Thanks to Steve Schmidt, Assistant Director of Adult Basic Skills Professional Development at Appalachian State University, we have the following translation.

WIOAs 13 Considerations in Plain English

  1. We serve students who most need our services, especially lower level students
  2. We serve individuals with learning and other disabilities
  3. We meet state student performance standards, especially at the lowest levels
  4. We and our partners work together to meet our local plan goals
  5. Our program lasts long enough for students to make progress, and we use research-based reading practices
  6. All of our instruction is based on scientifically valid research and best practices
  7. Our instructors use technology effectively for both classroom and distance learners
  8. We provide learning in context so individuals acquire skills to transition to post-secondary, obtain career/jobs and exercise their citizenship rights
  9. Our staff is well-trained and pursues quality professional development including through technology
  10. External partners help us create career pathways and support students to completion
  11. We offer flexible schedules and necessary support so our students succeed
  12. We keep an excellent student management system that reports student and program outcomes
  13. We teach ESOL and civics education to adults in our communities

How are you doing meeting the letter of the law in your program?