Public Comments Received on Career Pathways

On April 23, 2014, the Departments of Education (ED), Health and Human Services (HHS), and Labor (DOL) issued a Request for Information on Adoption of Career Pathways Approaches for the Delivery of Education, Training, Employment, and Human Services in the Federal Register. The request asked commenters to respond to 13 different questions regarding the design and implementation of career pathways systems. The comment period closed on June 9, 2014 and generated an impressive 142 public comments.

Respondents were diverse and included community-based organizations; national advocacy organizations; labor unions; local education agencies; industry associations; institutions of higher education; human service agencies; States; State and local workforce investment boards; State community college agencies; private individuals; and employers.

Full analysis of all comments is underway and more specific findings will be shared in the coming months. However, a preliminary review of the responses reveals several overarching themes:

Giving States and localities greater flexibility in the administration of education, training, and human services programs through waivers or other means was one of the strongest themes. Commenters emphasized the importance of ensuring that career pathway systems had entry-level “rungs” and supports that are accessible to low-skilled adults, as well as to adults who are English language learners. A number of commenters also expressed the view that more can be done to make career pathway systems accessible to persons with disabilities, youth aging out of foster care, veterans, and incumbent workers.

Another key theme was the need to better facilitate recognition of the prior knowledge, skills, and experiences of individuals, including granting college credit for knowledge and skills learned on the job through prior learning assessments, improving the articulation between two-year and four-year colleges, granting credit for the completion of non-credit training, and standardizing credentials across industry to improve the mobility of employees.

The benefits of establishing common performance measures across education, training, and human services programs was another repeated theme. Several commenters highlighted the common measures in the Workforce Innovation and Opportunity Act (WIOA) as a welcome development. The agencies also were encouraged to continue to support the development of integrated, cross-agency State data systems.

The necessity of interagency partnerships was another common theme; in the view of many commenters, Federal policy should continue to set clear expectations for cross-agency collaboration, as well as continue to offer technical assistance to States to help facilitate career pathway partnerships.

Finally, respondents highlighted many emerging and promising practices including strategies related to apprenticeship, accelerator programs, screening and assessment, using real-time labor market information, and much more.

This RFI marks the first time that the three departments are jointly collecting and analyzing information on “…the benefits of and challenges to aligning diverse funding streams, programs, and stakeholders around career pathway systems; and the current and potential future use of career pathways systems to help youths and adults gain skills and access the middle class.”

In related news, the three agencies hosted a National Dialogue on Career Pathways on September 23rd, where many of the same issues and concerns were raised. To hear a full recording, please click on “Web Cast Archive” at

As staff members from ED, HHS and DOL continue a deeper analysis of the 142 RFI responses as well as feedback from the National Dialogue, the agencies will share more important insights and formulate strategies to integrate these themes into shaping policy and technical assistance. So, stay tuned!

Photo of Johan Uvin
Posted by
Acting Assistant Secretary, Office of Career, Technical, and Adult Education
Posted by
Policy Analyst, OCTAE
Posted by
Director, Policy, Research, and Evaluation Services Division, OCTAE