1. Margie McHugh, MPI NCIIP
Ensuring Equitable Access for Immigrants and Refugees Seeking Workforce Services
Margie McHugh, MPI NCIIP
NCWE Conference
Atlanta, GA
October 12, 2016

2. MPI National Center on Immigrant Integration Policy
Primary Areas of Work:
Education and Training:
Early Childhood
K-16
Adult Education and Workforce Development
Language Access and Other Benefits
Governance of Integration Policy
© 2016 Migration Policy Institute 2

3. © 2016 Migration Policy Institute
Roadmap
Defining populations with equity concerns
Select equity challenges, opportunities under WIOA
Using population data as a lever for change
Using non-discrimination protections to improve service access for LEP individuals
© 2016 Migration Policy Institute 3

4. © 2016 Migration Policy Institute
Equity for whom?
Immigrants and refugees
Special focus on LEP individuals
Low-educated individuals
Those who are LEP and low-educated
© 2016 Migration Policy Institute 4

5. US Immigrants and Refugees
The foreign-born are:
15% of total population ages 16+ (nearly 38 million individuals)
Nearly 17% of US workforce (nearly 27 million individuals)
53% from Latin America; 28% from Asia; 13% from Europe; and 4% from Africa
Almost 1/4 unauthorized
© 2016 Migration Policy Institute 5

6. Equity and Access Under WIA
Extent of service access for foreign-born impossible to know; race/ethnicity not an appropriate proxy
However:
Only 1.2% of exiters in T1 adult intensive and training services were LEP (PY 2014)
Only 11.7% of exiters across all T1 adult services had less than a high school diploma/equivalent (PY 2014)
© 2016 Migration Policy Institute 6

7. © 2016 Migration Policy Institute
WIOA Equity Challenge: Most states serve small share of service-priority clients
Share without HSD/E in all Title I Adult Services (%)
Share LEP in Title I Adult Intensive/Training Services (%)
California
10.3
3.7
Florida
3.9
0.9
Georgia
6.2
0.1
Illinois
6.0
4.0
New York
12.2
Texas
13.2
1.1
Social Policy Research Associates, PY 2014 WIASRD Data Books: California, Florida, Georgia, Illinois, New York, Texas (Washington, DC: U.S. Department of Labor, Employment and Training Administration, 2015),
© 2016 Migration Policy Institute 7

8. Equity and Access Under WIOA:
Challenges
T1 programs’ historic reliance on English and HSD/E pre-requisites
Reliance on ITAs/community colleges and referrals from UI and social services for program clients
Lack of realistic pricing structure and performance timelines for programs serving clients with multiple needs
New performance penalty provisions may cause states to be risk averse
© 2016 Migration Policy Institute 8

9. Equity and Access Under WIOA:
Opportunities
Regression analysis: could help support states that serve clients with barriers; however, data limitations may undercut potential to do so
Automatic POS: intended to help drive services towards those with barriers; however, systemic approach needed to realize its promise
New anti-discrimination guidance: likely helpful, though more clarity (and final regs) needed
© 2016 Migration Policy Institute 9

10. © 2016 Migration Policy Institute
Advancing Equity and
Complying With WIOA
Equity Lever #1:
Use relevant population data to set expectations
© 2016 Migration Policy Institute 10

11. State and County Analyses of WIOA-Relevant Characteristics
Comparison of native- and foreign-born adults in the U.S. plus top 20 immigrant-receiving states and top 25 counties
Characteristics relevant to adult education and training needs: Nativity, age and region of origin; educational attainment; English proficiency; skill underutilization; poverty; family structure and parental status; immigration status
© 2016 Migration Policy Institute 11

12. Access MPI National or State
WIOA Fact Sheets
Arizona
Massachusetts
Pennsylvania
California
Michigan
Texas
Colorado
Minnesota
Virginia
Connecticut
Nevada
Washington
Florida
New Jersey
Georgia
New York
Illinois
North Carolina
Maryland
Ohio
© 2016 Migration Policy Institute 12

13. Select Counties Also Available
Alameda County, CA
Middlesex County, MA
Bronx County, NY
Montgomery County, MD
Broward County, FL
New York City, NY
Clark County, NV
New York County, NY
Cook County, IL
Orange County, CA
Dallas County, TX
Palm Beach County, FL
Fairfax County, VA
Queens County, NY
Harris County, TX
Riverside County, CA
King County, WA
Sacramento County, CA
Kings County, NY
San Bernardino County, CA
Los Angeles County, CA
San Diego County, CA
Maricopa County, AZ
Santa Clara County
Miami-Dade County, FL
Tarrant County, TX
© 2016 Migration Policy Institute 13

14. © 2016 Migration Policy Institute
Other Geographies
Ask MPI
Insert desired geography
Scroll to educational attainment table
© 2016 Migration Policy Institute 14

15. Limited English Proficiency and Educational Attainment
Limited English Proficiency and Educational Attainment (ages 16 and older), by Nativity,
Total
Native Born
Foreign Born
LEP Population by Educational Attainment
Number
Percent Native Born
Percent Foreign Born
Total LEP population
22,762,000
3,009,000
13%
19,753,000
87%
Percent
LEP population ages 16 to 18
519,000
259,000
100%
261,000
Not enrolled and no HSD/E
66,000
18,000 7%
47,000
18%
LEP population ages 19 to 24
1,623,000
392,000
1,231,000
With at least HSD/E
1,030,000
308,000
78%
722,000
59%
Without HSD/E
593,000
85,000
22%
509,000
41%
Enrolled in school
54,000
15,000
39,000 8%
Not enrolled in school and not employed
202,000
37,000
44%
165,000
32%
Not enrolled in school and employed
337,000
33,000
39%
304,000
60%
LEP population ages 25 and older
20,619,000
2,358,000
18,261,000
Less than HSD/E
9,647,000
909,000
8,738,000
48%
HSD/E
5,091,000
624,000
26%
4,467,000
24%
Some college or associate's degree
2,949,000
473,000
20%
2,477,000
14%
Bachelor's, graduate, or professional degree
2,932,000
352,000
15%
2,579,000
© 2016 Migration Policy Institute
Source:  MPI analysis of pooled ACS.

16. © 2016 Migration Policy Institute
Advancing Equity and
Complying With WIOA
Equity Lever #2:
Ensure non-discrimination provisions for LEP individuals are followed
© 2016 Migration Policy Institute 16

17. Language Access and WIOA
Title VI of the Civil Rights Act and Executive Order 13166: recipients of federal financial assistance must provide LEP individuals with “meaningful access” to services
July 2015 DOL guidance:
(a) A significant number or proportion of the population eligible to be served, or likely to be directly affected, by a WIOA Title I-financially assisted program or activity may need services or information in a language other than English in order to be effectively informed about, or able to participate in, the program or activity.
(b) In circumstances other than those described in paragraph (a) of this section, a recipient should nonetheless make reasonable efforts to meet the particularized language needs of limited-English-speaking individuals who seek services or information from the recipient.
© 2016 Migration Policy Institute 17

18. Language Access and WIOA
January 2016 NPRM:
“A recipient must take reasonable steps to ensure meaningful access to each limited English proficient (LEP) individual served or encountered so that LEP individuals are effectively informed about and/or able to participate in the program or activity.
“Whenever possible, the LEP individual’s access to the training program, and thus any resulting employment opportunity, should not be delayed by enrollment in an ESL course”
© 2016 Migration Policy Institute 18

19. Recap: Advancing Equity and
Complying With WIOA
Set equity expectations based on objective data
Leverage Priority of Service rules to improve access for LEP and no HSD/E individuals
Provide funding and TA for equity improvements
Prepare to shape federal regression analysis: improve and use program participant data; test barriers using program data
© 2016 Migration Policy Institute 19

20. Find data, reports and other analysis by state and for the nation at
Thank you—let’s stay in touch!
Margie McHugh
Madeleine Morawski
Find data, reports and other analysis by state and for the nation at
© 2016 Policy Institute