Commentary by Melinda Mack on NYS Comptroller's Report on Workforce Fragmentation

On May 19, 2022 the NYS Comptroller's Office published “Overlap, Duplication, Gaps, and/or Fragmentation in Workforce Development Programs and Services" (you can read the full report at the Following LINK).  The findings include:

• We identified more than 500 WFD programs and services that are offered by 22 State agencies and public authorities. Despite the number and variety of these services, weaknesses in the System, including a governance body that has been dormant for 5 years and a delay in approval of the guiding Plan for WFD in New York, render it inadequately positioned to address the State’s workforce needs.
• In the absence of a functioning SWIB, the Department and its partners may not be adequately considering the needs of job seekers and employers, and the risk of overlap, duplication, gaps, and/or fragmentation in programs and services increases.
• The Department has not updated its “Catalogue of Funding” since August 2019.

I agree with the Comptroller's assessment of the critical importance of having a functioning State Workforce Development Board, and the importance of transparently providing information via the Catalog of Funding on an annual basis. These are two areas of advocacy NYATEP has pursued for decades. However, while we are often the first to point out the room for improvement in New York, I would like to be clear that  this report misses the mark and important context as it relates to system ‘fragmentation’.

The report outlines several recommendations, but the report reinforced the overarching lack of understanding of the context, requirements, and sophistication that is required to support both workers and businesses across New York. There is not a simple solution to the complex problem of continuously upskilling the State’s workforce, to the current and future labor market’s standards, while addressing historic and systemic racism and poverty.  It is unhelpful to make an argument that the system is fragmented, without providing this context.

The Comptroller’s report identified more than 500 WFD programs and services that are offered by 22 State agencies and public authorities, including what funding and populations the programs serve. However the report lacks a crucial detail: the definition of workforce development utilized to determine what is included in this report and what is excluded. For example it is unclear why two New York City Offices were called out, but not other local agencies; many non-credit college job training programs are included – but so is the Next Gen Linkage program which supports matriculated students' connection to employment.

The report does get right the needs for improved data collection and common metrics across the diversity of workforce programs in New York. We have called on the State to set goals and measure outcomes for decades. But, it is crucial that we tell the story accurately, which means the system must respond to the varying needs by population, sector, and region. For example, a program intending to serve a low income, 16 year old lacking a High School diploma requires a different timeline, educational/skill building and supportive services as opposed to someone who was recently released from prison with little work experience and significant stigma to overcome before being hired. To insist workforce development be monolithic is a failed approach.

Finally, the Comptroller’s report suggests that every county should have a brick and mortar American Job Center, or “career center”. Many local workforce areas have been working to expand their reach and reduce duplication of services, by providing virtual services, partnering with community-based organizations, or other mandated partners to deliver services locally.  Much of this coordination cannot be counted using the current data system.  Furthermore, under WIOA, each of the Local Workforce Development Areas is required to have only one comprehensive American Job Center, and they do. The federal law provides flexibility for the local workforce system to determine the best and most cost effective structure to support the needs of the local community. To me this means allowing the people on the ground, who know their businesses and their residents best, are empowered to make the decisions about how best to meet their needs.

Let us know what you think of the report by tweeting @NYATEP on Twitter.

About the Author: Melinda Mack is NYATEP's Executive Director. To learn more, visit NYATEP.org