Remember – These notes
don’t represent any official position of the Delaware Workforce Investment
Board or the Delaware Department of Labor. Rather they are my personal thoughts
and only represent my opinion.
There is a kerfuffle brewing.
With the passage and signing into law of the Workforce
Innovation and Opportunity Act the inevitable creation of a DOL regulation to
cover the law is, or will soon be, underway by well meaning Employment and
Training Administration (ETA) professionals.
One school of thought is that workforce professional should
be careful about commenting on proposed regulations because in the words of one
person, housed in DC, “You can’t fight about everything. We need to pick our
battles.”
There is another valid school that says, “This is an
innovation act and we should be careful and not let ETA put so many
restrictions into it that it looks like a WIA (Workforce Investment Act) redo.”
This school of thought comes from local and/or state workforce professionals
administering programs at the end-user level.
Both schools seem valid, but I tend to lean toward the
school that promotes questioning regulations in the comment period to ensure
issues are addressed early. Since language matters, (and I believe it does)
local and state boards need to review the law, discerned its intent, and be
prepared to argue – with respect and clarity – where proposed regulations are
faulty.
Again, this is just my opinion, but I intend to watch the
comment period closely.
Bill
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