Letter in Opposition to HR 6861, the Consolidating Veteran Employment Services for Improved Services Act

Re: Opposition to HR 6861

Dear Chair Van Orden and Ranking Member Pappas,

On behalf of the National Association of State Workforce Agencies (NASWA), we write to express concern over HR 6861, “Consolidating Veteran Employment Services for Improved Performance Act,” that would amend Title 38, United States Code, to transfer certain functions from the U.S. Department of Labor (USDOL) to the Department of Veterans Affairs (VA).

As a non-partisan organization whose members are the workforce agencies in all 50 states, the District of Columbia, and U.S. territories, NASWA brings a unique and diverse perspective to the challenges facing our nation’s workforce. Our members are on the frontlines of service delivery for a range of workforce programs including Veterans employment and training. NASWA’s Veterans committee includes Jobs for Veterans State Grant (JVSG) coordinators and staff from all the workforce agencies in the states, the District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands.

We are concerned HR 6861 would move JVSG and related Veterans programs such as USERRA and HVRP out of USDOL Veterans Employment and Training Service (VETS) to the VA. NASWA believes it is critical to maintain and safeguard the vital role of Veterans’ programs in the workforce development system. The state workforce system is best suited to serve Veterans, Transitioning Service Members, and military spouses/caregivers because of its alignment and integration of employment and career services and access to other state and federal workforce programs found in the American Job Centers (AJCs).

As written, HR 6861 leaves many questions unanswered as to where or how Veterans would receive workforce services. Currently, Veterans, service members transitioning out of the military, and their spouses have access to a wide variety of employment and training services through each state’s one-stop center system, the American Job Centers (AJCs). This integrated approach to service delivery affords Veterans no-cost access to employment and re-employment opportunities, resume assistance, training, case management, job search assistance workshops, unemployment insurance, Workforce Innovation and Opportunity Act (WIOA) training dollars, the Work Opportunity Tax Credit certification, public assistance such as SNAP and TANF, supportive services, and numerous partner services and community resources at one location – regardless of disability, educational level, economic status or employment barrier.

The current model allows for co-enrollment in multiple programs to provide access to services based on the Veterans’ need. All AJC staff – not just the JVSG-funded personnel – are also responsible for ensuring Priority of Service (POS) is provided to Veterans for all USDOL funded employment and training programs such as WIOA administered by the USDOL Employment and Training Administration. POS ensures veterans or eligible spouses either receive access to these services instead of or before non-veterans or non-covered persons. HR 6861 makes no reference to this guarantee.

Under current federal law, separating service members and military spouses generally qualify as dislocated workers and can receive help entering or reentering the workforce under the Workforce Innovation and Opportunity Act (WIOA) Title I. WIOA expanded the definition of dislocated workers to include military spouses who lost employment as a direct result of a relocation to accommodate a permanent change in the service members’ duty station. WIOA Title I is a DOL program, and access to WIOA funding and assistance is available to these affected individuals through the 2400 American Job Centers located across the nation.

If changes to this integrated service delivery model described above were made, they would be disruptive and costly to the public workforce system customers and staff, and to partner affiliations. Unlike the VA, the USDOL has decades of experience focusing on employment. Moving workforce services from USDOL to the VA could require the creation of a new and costly additional reporting and data management systems, development of new data sharing agreements, and a change in the creation and collection of performance metrics. HR 6861 would require the VA to enter into memorandums of agreement with the states, a requirement that does not currently exist. This bill does not reference services to Transitioning Service Members and military spouses/caregivers, populations currently served in the AJCs, and it would be inefficient to serve these populations separately.

We also have concern that HR 6861 would disrupt the staffing of services to Veterans.

JVSG services for Veterans are currently performed by specially trained staff known as Local Veteran Employment Representatives (LVERs), Disabled Veteran Outreach Program specialists (DVOPs) and Consolidated DVOPs/LVERs (CODLs). As written, the bill requires these functions to be combined into one position, the “Veteran Employment Specialist,” diluting the targeted approach and expertise the current model provides. Consolidated positions are currently used when appropriate for a state, especially in rural areas.

HR 6861 provides no assurance that existing trained staff – who are veterans and disabled veterans themselves - would be retained by a VA model, resulting in a loss of years of experience and knowledge. Currently, all JVSG staff are required by statute to complete job specific training within 18 months of hire and are afforded multiple training opportunities through an established and experienced training provider, the National Veterans Training Institute (NVTI).

A host of other concerns exist, as this bill would result in a fragmented service delivery model that would not benefit Veterans, employers, taxpayers, or military families, and create barriers for Veterans seeking employment assistance and career guidance in their transition to civilian life.

NASWA opposes HR 6861 as currently written. NASWA stands ready to work with the Committee to make improvements to the bill to enhance and improve employment services for Veterans.

Sincerely,

Scott B. Sanders
President and CEO