Private Vocational Schools Collaborative
Project Report
Gap Analysis, Summary, and
Recommendations
November 2017

Karen Ahrens
L&I Liaison to the Workforce Training and Education Coordinating Board
Department of Labor and Industries
Insurance Services, Return to Work Partnerships, Private Sector Compliance

 Table of Contents
Executive Summary………………………………………………………………………...…… 1
Introduction ……………………………………………………………………………...………. 4
Background Information………...………………………………………………….…….……..5
The Problem……………………………………………………………………………...…….….8
The Project…………………………………………………………………………………......... 15
Best practice guidelines ………………………………………………………………………… ....16
School visits - A tale of four schools .....................................................................................17
Identifying customer expectations.………………………………………….............….…………18
Focus groups…………………………………………………………………………………………18
Review of injured worker claims…………………………………………………….…………......20
Determining solutions to retraining gaps…………………………………………………….…… 21

Recommendations …………………………………………………………………………...... 22
Conclusion…………………………………………………………………………………......... 24
Figures
Figure 1: Comparison of training options ………………………………………………………….5
Figure 2: Training schools chosen by L&I injured workers……………………………………….6
Figure 3: Comparison of retraining program completion rates…………………………………..7
Figure 4: Private Vocational Schools Collaborative Project Best Practices Guidelines..........16
Figure 5: Career Bridge website information - General office, accounting/bookkeeping, and
medical office/receptionist certificates……………………………………………………………..31
Figure 6: Career Bridge website information – Trucking certificate………………………….…32

Appendix A: Educational Standards for Schools...................................…...………......25
Appendix B: Workforce Training and Education Coordinating Board...………...........27
Appendix C: Career Bridge website and Eligible Training Provider (ETP) list...….....30
Appendix D: Helpful links……………………………………………………………….......... 34

 Executive Summary
The Department of Labor & Industries (L&I) protects the safety, health, and security of
Washington’s workers and citizens. As part of this mission, the agency administers Washington’s
workers’ compensation system, which provides benefits to workers who are injured on the job or
who suffer from an occupational disease. It pays for medical treatment, partial wage replacement and
provides disability benefits. For eligible workers, training for a new job or occupation (vocational
rehabilitation) is also provided.

The problem
Despite improvements made by the 2008 Vocational Improvement Project, over 50 percent of injured
workers who begin a retraining plan do not complete it. For those who do complete a plan, the return
to work rate is less than 30 percent.
The project
The one-year Private Vocational Schools Collaborative Project began, in February 2016, in response
to stakeholder concerns about low completion and employment rates for injured workers who attend
vocational training particularly from private schools. L&I collaborated with the Workforce Training
and Education Coordinating Board (Workforce Board or WTECB) on this project to:
 Assess the efficiency of private vocational schools in preparing workers to reenter the job market
 Identify gaps in the retraining process
 Recommend and/or implement solutions to address retraining gaps
Research methodologies used in this project included school visits to evaluate use of best practices,
focus groups, and claim data analysis.
A project advisory committee was formed and met quarterly. Committee members included
representatives from the Workforce Board, private vocational counselors, and L&I staff.

Assessing the effectiveness of private vocational schools (PVS) in preparing
injured workers to reenter the job market. Identifying the gaps.
There is wide variation in the quality of the training programs available to workers:
 There are a number of recognized, accepted and desirable best practices for private schools;
however, our system currently lacks the basis to require that a school report or adopt them.
 The private schools that our injured workers attend most often show little or no evidence of using
best practices.
 Some of these schools lack realistic entrance requirements. In addition, some of these schools do
not objectively assess skill attainment during and upon completion of a program.

1

 There are gaps in the establishment, available information and oversight of quality standards for
private vocational schools that are not accredited.1 Injured workers, vocational counselors and others
do not have ready access to information about the quality, completion and employment rates of many
private vocational school programs.
 Licensed schools are not required to make available completion and employment data, although
this data is sometimes available for schools with programs on the state’s Eligible Training
Provider List.
 At the time of licensing, the Workforce Board requires schools to meet multiple requirements
including providing a detailed business plan, demonstrating financial stability, and providing an
overview of their curriculum and the qualifications of instructors.
 They have a regulatory process for schools who violate rules regarding unfair business practices
but they do not have a subsequent focus on quality assurance beyond requiring schools to report
completion and employment data, which may or may not be published.2

Determining solutions to gaps in the vocational retraining process
L&I used the information gathered from school visits, focus group feedback, and review of injured
workers’ claims to help pinpoint the causes of low training plan completion and return to work rates.
Information gathered during this project indicates that:
 A worker may choose a job goal without a full understanding of quality training options
available. The Eligible Training Provider (ETP) list could serve as a measure of quality to help
injured workers evaluate which schools and programs have the best chance of leading to a
desired job. However, schools are not required to report programs and data on the ETP unless
students attending that program are utilizing federal funding.
 Adopting and implementing use of the best practice guidelines for private schools, developed as
part of this project, could provide workers and vocational rehabilitation counselors (VRCs) with
a systematic method to compare options and evaluate quality.
 Workers with multiple barriers to reentering the workforce, as well as residual effects from their
industrial injury, face specific challenges with education. Piloted use of a multiple barriers (MB)
list when evaluating injured workers should be considered as part of a project involving
interested vocational staff, VRCs, and some private schools utilizing best practices, including job
placement services.

Earlier Vocational Retraining for those who need it
In recent years, L&I has stepped up efforts to provide vocational services sooner after a worker is
injured. While this has resulted in more workers returning to work, it also means that those eligible
1

Accreditation is not a requirement to become a licensed private vocational school. Private vocational schools referenced in this
report are licensed by the state and tend to be smaller and provide focused career training in just a few areas. In contrast, larger
private-sector schools and colleges are accredited by accrediting organizations recognized by the USDOE primarily for the purpose
of receiving federal financial aid. http://www.wtb.wa.gov/PCS_StartingASchool.asp
2
See RCW 28C10.110 Intent: It is the intent of this chapter to protect against practices by private vocational schools which are
false, deceptive, misleading or unfair, and to help insure adequate educational quality at private vocational schools. See also
chapter listing WAC 490.105: Regulation of Private Vocational Schools, including WAC.490.105.140 Initial School Licensure
Requirements and WAC 490.105.170Unfair Business Practices.

2

 for retraining begin receiving these services earlier, when motivation is higher and long-term
disability may not have set in.
Although we do not have robust evidence in our system yet, we theorize that getting workers who do
need training into training earlier may help improve those workers’ success at completing a program
and getting a job.

Recommendations
It is essential to shift the definition of training success from a focus on plan completion alone to plan
completion and finding a job. Specific recommended actions include:
 Improve informed choice for workers:
Lack of access to job and completion rates hinders informed choice. To help ensure injured
workers receive training that leads to a desired job, L&I should consider requiring injured
workers to select education programs exclusively from the ETP list as one measure of quality.
L&I should also continue to encourage workers and VRCs to use employment and labor market
resources offered through WorkSource, the state’s one-stop career center system, when selecting
a retraining plan goal that is likely to lead to employment.
 Ensure adoption of best practices:
L&I should consider requiring the schools that train injured workers to show evidence that they
have incorporated identified best practices, as a means of helping ensure student success in
completing the program and obtaining employment.
 Assess the quality of schools on an ongoing basis:
This would apply to all schools that train injured workers. Continue to refer schools and
programs that are not licensed but should be licensed to WTECB.
 Address workers with unique and/or multiple barriers to reentering the workforce:
Workers with barriers to reentry to the workforce, as well as residual effects from their industrial
injury, face specific challenges with education. VRCs should effectively assess each worker’s
strengths, abilities and needs, to ensure a good fit with a proposed program. Particularly, injured
workers with limited English proficiency and adult basic education needs may not be getting
these needs met fully. L&I should consider
 Piloting use of a barriers list when evaluating injured workers.
 Provide early access to accredited English as a Second Language (ESL) and Adult Basic
Education programs.

In Conclusion
This project has identified a number of issues that can interfere with a worker being successfully
retrained and job ready. We recommend that a system be developed that requires all private
vocational schools and all unlicensed or non-accredited programs that work with L&I to meet certain
best practices and data reporting requirements. We further recommend the identification of effective
(evidence based) practices when identifying and addressing a worker’s abilities, needs and potential
barriers to retraining. Finally, our system needs a better method for evaluation of training options
that will lead to gainful employment.
3

 Introduction
The Department of Labor & Industries (L&I) is pleased to provide this report describing the Private
Vocational Schools Collaborative Project Gap Analysis, Summary and Recommendations. This
study assesses training offered to injured workers who lack transferrable work skills because of their
injury, and provides recommendations to address gaps in the training.
Washington’s workers’ compensation system provides benefits to workers who are injured on the job
or who suffer from an occupational disease. It pays for medical treatment and partial wage
replacement and provides disability benefits. For eligible workers, training for a new job or
occupation (vocational rehabilitation) is also provided.
Since 2008, the vocational rehabilitation system has undergone substantial changes to improve
vocational outcomes for Washington’s injured workers and employers. The Private Vocational
Schools Collaborative Project proposes to build on those improvements.
This report describes the results of the project assessment and summarizes recommendations for
improvement.

4

 Background Information
The goal of retraining injured workers is to give them the knowledge and skills necessary to be
readily and gainfully employable in the labor market. About 75 injured workers enter into retraining
programs each month, with about 1,800 currently engaged in retraining.
In 2008, L&I’s Vocational Improvement Project (VIP) resulted in major changes to workers’
compensation vocational rehabilitation benefits that support training to eligible workers. These
changes included extending the time for accessing training from one year to two years, and raising
the cap for tuition benefits from $4,000 to (currently) $17,500. The VIP also increased the variety of
training options available, and offered greater flexibility for workers to self-manage their training
benefits.3
A worker eligible for training is assigned a vocational rehabilitation counselor (VRC) to help develop
a training plan. After L&I approves the plan, the worker has 15 days to choose one of two ways to
use their benefits, as shown in Figure 1 below.

Figure 1: Comparison of training options
Option 1

Option 2

Worker participates in approved training with Worker receives a vocational award equivalent to
nine months of time-loss benefits, and has access
oversight by a vocational rehabilitation
counselor.
to funds for self-directed training for up to five years
and the ability to use up to 10% of the retraining
funds for job placement and vocational counseling
services.
Claim remains open until training is
completed.

Claim is closed.

Source: Revised Code of Washington 51.21.095, Washington Administrative Code 296-19A.090
and 296-19A.110.4

Injured workers entering a training program can attend either an accredited public or private degree
granting school – usually a community college funds
certificate
program – or a licensed private vocational
for job placement and counseling services.
school (PVS) with a certificate program. While accreditation is voluntary in Washington State,
community colleges are accredited per the Northwest Commission on Colleges and Universities.
(NWCCU).5 Private schools must be licensed, but accreditation is not required. Accreditation and

Workers’ Compensation Vocational Rehabilitation System Annual Report to the Legislature 2014, December 2014.
Private Vocational Schools Collaborative Project, Baseline data, July 2016. Includes out-of-state schools.
5
State standards for quality at all state agencies including community colleges is governed by RCW 43.17.390 Quality
management, accountability, and performance system—Independent assessment. Washington Association for Community
and Technical Colleges (WACTC) and State Board for Community and Technical Colleges (SBCTC) in 2008 requested that
Northwest Commission on College and University (NWCCU) accreditation would be recognized as satisfying the Washington State
Quality Award standards under RCW 43.17.390.
3
4

5

 licensing have different educational standards and methods for ensuring compliance. (Appendix A:
Educational standards for training schools).
Certificate programs verify that a person has received specific education or has passed a series of
tests related to a specific occupation, and meet the needs of many workers. Private vocational schools
offer industry-specific programs as diverse as welding, trucking, bartending, barbering and
cosmetology, construction estimator/project manager, computer technician, home inspection, realtor,
manufacturing, warehousing, emergency medical technician, phlebotomy, and flagger. A worker can
sometimes identify an unusual job goal such as jewelry maker with help of their VRC. Less often, a
VRC may help a worker find an On-the-Job (OJT) training program. In all cases, VRCs are to ensure
that there is a labor market consistent with the worker’s physical abilities.
Figure 2 shows the schools chosen by injured workers found eligible for training benefits in 2015.
Nearly one in five injured workers entering a training program attended a PVS. Only a few PVS
show more than one or two enrollees per year. This appears consistent with previous years.

Figure 2: Training schools chosen by L&I injured workers

Private Vocational
School Students, 383
18%
Community College/ Public
School Students, 1729
82%

Data includes out of state schools. Data source: Labor and Industries Research and Data Services 6.

According to 2012-2015 data, the average length of an injured worker’s vocational plan is 528 days
at a public college and 491 days at a PVS. The average cost of completing a training program was
$12,874 at a public college and $12,500 at a PVS. Plan completion rates were 46 percent at a public
college and 57 percent at a PVS. A few injured workers who attend college attain a two or four-year
degree, but the majority graduate with a certificate level credential from a community college or
from a PVS.7

6

Private Vocational Schools Collaborative Project baseline data, July 2016. Data includes out of state schools. Data source: L&I
Research and Data Services.
7
Private Vocational Schools Collaborative Project, Baseline data, November 2016. Data includes out of state schools. Data source:
L&I Research and Data Services.

6

 Retraining program comparison
The overall average completion rate for retraining plans is consistently about 54 percent. Figure 3
shows these rates are comparable to or better than completion rates for other types of adult training.
Figure 3: Comparison of retraining program completion rates

2011 Completion Rates of 8 Retraining Programs
Workers' comp success rate is as good or better than other retraining programs
VA - Veterans Administration

60%

WA State Workers’ Compensation

54%

DVR - Division of Vocational Rehabilitation

47%

CTC - Community and Technical Colleges

45%

WA WorkFirst

45%

WA State Apprenticeship

42%

Washington State Public Universities

41%

WAWorker Retraining

41%

0%
10% 20% 30% 40% 50% 60% 70%
Sources: L&I Research and Data Services. Vocational Non-Completion Plans Draft Report, August 2011,
Sidse Nielson and Janice Orcutt.8

8

Vocational Non-Completion Plans Draft Report, August 2011, Sidse Nielson and Janice Orcutt. Data source: L&I
Research and Data Services.

7

 The problem
Despite improvements made by the 2008 Vocational Improvement Project, nearly 50 percent of
injured workers who begin a retraining plan do not complete it. For those who do complete a plan,
the return to work rate is less than 30 percent.9
In 2011, L&I undertook a review of specific claims to evaluate vocational plan non-completion. The
study posed these questions:
 What are the common reasons for plan non-completion?
 Could the plan have been salvaged?
 What worker characteristics are associated with plan non-completion?
This study found that there are multiple factors contributing to non-completion of vocational training
plans. While medical factors in a claim, whether due to the accepted condition(s) or unrelated, had
the largest impact on plan non-completion, grades and attendance and school changes, including
access to classes, were also significant. Incidental findings showed the length of vocational plans also
factored into both completed and non-completed plans. Proportionally, shorter plans of one year or
less had higher success rates than longer plans. The factors that may contribute to plan noncompletion fall into several categories:
 Interruption to the vocational plan that is outside the control of the injured worker10, which
accounted for 60 percent of plan non-completion (when a worker meets the criteria for this
reason for non-completion, the law allows them to continue with training efforts)
 Change in claim-related or non-claim-related medical status
 Opioid use
 Psychiatric issues
 Poor grades and attendance
 School changes such as dropping a class or program from the schedule
Sometimes these factors are also present in successfully completed plans. The focus of this project
was to explore school-related gaps in the retraining process. We believe that developing better
support for student success (via both schools and VRCs) can help impact these factors when they
arise, and result in more workers completing their plans.

Problems identifying and accessing quality educational/training programs
Post-secondary education is a complex system in and of itself. While some private vocational school
choose accreditation, accreditation is not a requirement. A few PVS in our state are accredited and
licensed but most are only licensed. Accreditation and licensing have different standards and
methods for ensuring compliance. Public or private accredited schools generally have more
9

Data Source: L&I Research and Data Services. Research conducted as part of the Vocational Improvement Project
A vocational plan interruption is considered outside the control of the worker when it is due to the closure of the accredited
institution, when it is due to a death in the worker's immediate family, or when documented changes in the worker's accepted
medical conditions prevent further participation in the vocational plan. (RCW 51.32.096(5) (b).
10

8

 information available on educational quality and outcome measures. Most public schools attended by
injured workers seeking vocational training are accredited degree granting community colleges.
Most programs attended by workers at community colleges are certificate level and not degree
programs. All PVS must be licensed unless they fall under Workforce Boards’ rules for Private
School’s exemption from licensing requirements.11 Evaluating quality educational offerings is
confusing.

Workforce Training and Education Coordinating Board
Part of the mission of the Workforce Training and Education Coordinating Board (Workforce Board)
is to bridge the gap between skills of graduating students and the skills employers want. For industry
to thrive, workers must be properly trained and equipped with the skills that businesses require. For
Washington workers to prosper, they need to be able to secure stable, living-wage jobs that can grow
into lifelong career pathways. Programs that track graduates’ completion, employment rates and
earnings, by meeting the federal Eligible Training Provider (ETP) list baseline criteria offer one
marker of quality.
The WTECB agency is governed by a Workforce Board. The state’s Workforce Board includes nine
voting members, made up equally of business, labor and government representatives, who regularly
come together to help create a coordinated, more effective workforce system on behalf of
Washington’s workers and businesses. Agency staff focus on policy, planning, and strategic
initiatives that make a positive impact on the system.
The agency created and maintains the Career Bridge website, a nationally recognized website that
recorded over 9 million page views last year, and continues to grow. The site is used every day by
jobseekers and counselors in the state’s WorkSource center system and is used by middle and high
school students seeking information on careers, college programs and apprenticeships in Washington,
as well as ways to pay for school.
Agency research staff regularly evaluate the performance of the state’s largest workforce programs,
leading to further system improvements. Research staff also independently evaluate thousands of
education programs for inclusion on the state’s ETP list on the Career Bridge website. Staff
independently evaluate completion rates, and employment and earnings for recent graduates, using
student data records provided to the agency. These records are matched against wage files from the
state’s Employment Security Department, creating “consumer report cards” on many education
programs that are then pushed out to the public via Career Bridge.
In addition to policy and research work, the Workforce Board also includes a Consumer Protection
Unit that licenses and regulates private career schools that offer short-term, career-focused training,
below the degree level. The Workforce Board does this regulatory work in tandem with the
11

Licensed Private Schools must design and implement programs of quality, content, and duration, and with appropriate entrance
criteria, instructional materials, staff, equipment and facilities to prepare students for the program's occupational objectives. WAC
490-105-150. At the time of renewal, each licensed PVS must submit a description of programs and course offerings in accordance
with WAC 490.105.100 WAC 490.105.150.

9

 Washington Student Achievement Council, a state agency that authorizes private degree-granting
institutions. Cosmetology schools are licensed by the state’s Department of Licensing. The
Workforce Board and Washington Student Achievement Council also provide regulatory oversight
for veterans’ training programs.12
Consumer protections for licensed schools include a student complaint process and a Tuition
Recovery Trust fund, which private careers school pay into, in the event of a school closure or a
complaint of unfair business practices. The Workforce Board typically licenses over 300 private
vocational schools in our state, a number that fluctuates as new schools open and some close. Each
licensed PVS is held to minimum standards of initial school licensure requirements as well as
minimum standards of annual license renewal requirements. These requirements include providing a
detailed business plan, demonstrating financial stability, and providing an overview of their
curriculum and the qualifications of instructors. It is not required for PVS to be on ETP list13
(Appendix B: Workforce Training & Education Coordinating Board and Appendix C: Career Bridge
and Eligible Training Provider (ETP) List)
The Workforce Board has been tasked with management of the Eligible Training Provider list under
the federal Workforce Innovation and Opportunity (WIOA) Act in our state. WIOA reauthorizes and
amends the federal Workforce Investment Act (WIA). The Workforce Board partners with 14
regional Workforce Development Councils and the state’s Employment Security Department, which
together oversee local WorkSource offices. Those who are eligible for federal training dollars
through WIOA, must choose programs from the state’s Eligible Training Provider list that meet
certain performance thresholds. In addition, those who receive state Training Benefits funding from
the Employment Security Department to train for a new career must select programs from the ETP
list. Schools that wish to be eligible for these federal and state training dollars must submit data to the
Workforce Board to evaluate performance, including completion rates, employment and earnings.
Participation on the ETP list is voluntary for schools and colleges, both public and private.14
Individuals often find out about WIOA benefits by visiting local WorkSource employment centers.
The mission of WorkSource is to serve job seekers and employers in hiring skilled workers.
WorkSource offers job seekers access to job postings and tools. WorkSource also provides assistance
with skill and related assessments, resume writing, interview and job search skills, and job placement
assistance. Employers get unlimited posting capacity and automatic referrals.
Injured workers have access to WorkSource assistance at one-stop service locations, through the
WorkSourceWa.com website, and L&I VRCs at some locations. L&I’s claim-assigned VRCs often
refer injured workers to WorkSource as an additional resource. Six L&I vocational services staff are
located at local WorkSource offices and two ESD WorkSource return-to-work specialists are situated
within Claims Administration. (Appendix B: Workforce Training & Education Coordinating Board.)
12

Workforce Training and Education Coordinating Board: http://wtb.wa.gov/WorkforceBoard.asp.
Workforce Training and Education Coordinating Board: http://wtb.wa.gov/WorkforceBoard.asp.
14
Workforce Training and Education Coordinating Board, Washington Workforce Development Services System Poster.
http://www.wtb.wa.gov/WorkforceDevelopmentDirectory.asp
13

10

 Career Bridge and the Eligible Training Provider List
Career Bridge (www.CareerBridge.wa.gov) is the free state website, created and managed by the
Workforce Board, which informs students and jobseekers about over 6,500 education programs
including month’s long training programs to one-year certificates, two-year associate’s degrees, fouryear bachelor’s degrees, and beyond. The site also features registered apprenticeships. Career Bridge
offers users data on completion and employment rates, graduates’ wages, and the industries where
they went to work for some schools’ programs. It also offers a prospective student additional
information including data on in-demand jobs, school tuition rates, and length of programs.
Performance results can be found for approximately a third of the 6,500 programs listed on Career
Bridge. Schools that choose to be evaluated for inclusion on the ETP list submit their data to the
Workforce Board, where research staff evaluate programs for performance with the results posted on
Career Bridge. As noted previously, a school is not required to report data on the ETP unless the
students attending that school utilize federal or special state funding.15.
In 2014, Governor Inslee adopted the most recent ETP criteria to determine training program
eligibility, with thresholds set by the Workforce Board16 ETP is a federal requirement from the U.S.
Department of Labor under the 1998 Workforce Investment Act, and now updated under WIOA. To
be entitled to federal funding through WIOA, an education program must meet performance
thresholds and be on the state’s ETP list. This means it meets or exceeds certain baseline
performance standards for program completion, employment, and earnings. The ETP standards are
described in Appendix C: Career Bridge and Eligible Training Provider (ETP) List 17
L&I rules require workers to obtain vocational training at a licensed or accredited school. They set
stringent exception criteria for unlicensed or non-accredited programs. In 2015, L&I worked with the
Workforce Board on rule changes to benefit injured workers and other agency-sponsored students of
PVS. Some licensed schools that in the past focused exclusively on recruitment of injured workers
were considered community-based, and were exempt from regulations and data submission. The
revised rules aligned the policies of the two agencies. Agency-sponsored students from L&I and the
Department of Vocational Rehabilitation are now covered by the Workforce Board’s consumer
protection regulations. However, L&I rules do not require VRCs to use ETP-listed programs.
Despite these improvements, complaints, investigations, and other stakeholder feedback indicate
some private schools may not be delivering the quality education and job preparation our vocational
system needs. Stakeholder complaints were almost exclusively about licensed schools rather than
public (state) or private accredited institutions.
Historically, L&I had not focused on assessing or monitoring the quality of education and job
preparation provided by PVS. The U.S. Department of Education regulates accreditation of training
15

Workforce Training and Education Coordinating Board: http://wtb.wa.gov/WorkforceBoard.asp.
Current thresholds adopted by the Workforce Board for programs to be on the state’s Eligible Training Provider list are 20 percent
completion, 50 percent employment rate and $3,943 in a calendar quarter (three month period) or $10.64 per hour. See Appendix C:
Career Bridge and the Eligible Training Provider (ETP) List for more detailed information.
17
Workforce Training and Education Coordinating Board, Eligible Training Provider Performance Policy:
http://www.wtb.wa.gov/Documents/Tab3-ETPLS.
16

11

 programs. Other rules on program quality and integrity are complex and do apply to either licensed
private vocational schools and programs or non-degree programs at community colleges.
Accreditation standards have been in the news lately with the decertification in June 2016 of
Accrediting Council for Independent Colleges and Schools (ACSIC) and the recent closure of ITT
Technical Institute campuses in many states. Measures of cost and quality education remain at the
heart of federal regulations. Federal scrutiny on quality education has focused on student loan debtto-earnings ratios. Injured workers do not take on student debt, but have an equal need to use their
vocational benefits for quality education and skill attainment.18
Questions on the role of quality post-secondary education are not limited to our state. A recent article
outlines the current controversy over whether a public school or private school certificate guarantees
a higher salary based on recent U.S. Department of Education data.19 Further regulations,
modification of existing regulations and clarification of program integrity rules may be forthcoming
at the federal level in the near future. The U.S. Department of Education has recently released a
second set of gainful employment rules setting a baseline for schools with the intention of capturing
the majority of poor performing programs through scrutiny of graduates’ employment outcomes
compared to amount of student debt. Along with gainful employment, distance education standards
are currently in development.

Gaps in the retraining process when evaluating PVS
Gaps exist in the establishment, available information about, and oversight of quality standards for
private vocational schools that are not accredited. Injured workers have a guaranteed amount of
educational benefits to expend for post-secondary training programs at a community college or at a
PVS, but no systematic way to compare programs. An ETP-listed program is required for WIOA
funding, but is not required for workers’ compensation vocational retraining. There are a number of
additional recognized, accepted and desirable best practices for private schools (see Figure 5 on page
32); however, our system currently lacks the basis to require that a school report on or adopt these
best practices.
VRCs assess each worker’s strengths and needs in an effort to match them to the best program, but
this does not make up for the lack of standard markers of quality. The Workforce Board Consumer
Protection Unit licenses and regulates PVS, but does not provide quality assurance for licensed
schools. There are minimum standards11 that each school must follow to renew their license each
18

For Profit Schools Seek Reprieve on Gainful Employment Rule from Inside Higher Education, April 16, 2016, and Public
Sector Certificates Result in Higher Earnings than Those from For Profits, Andrew Kreighbaum and Ashley A. Smith,
https://www.insidehighered.com/news/2016/11/18/education-department-releases-gainful-employment-data-vocational-programs.
Inside Higher Education, Andrew Kreighbaum and Ashley A. Smith, November 18, 2016: “Earnings data the U.S.
Department of Education released Thursday show that graduates of certificate programs at public institutions earned nearly $9,000
more than graduates of those programs at for-profit colleges. The colleges. The department will use the new numbers to enforce its
gainful employment rule, which was finalized in 2014 and seeks to measure whether a sufficient number of graduates of vocational
programs can repay their federal loans. The data also showed a wide range of variation in earning outcomes depending on a
graduate's field of study. That variation partly explains the difference in earnings between certificate holders who attended public
and for-profit colleges. Those who attended higher-earning certificate programs were more likely to have attended a public
institution, such as a community college.”
19

12

 year and there is a student complaint process for unfair business practices. Some of the private
schools that workers attend most often show little or no evidence of using best practices. Examples
of some of the problems needing to be addressed included non-accredited English as a Second
Language (ESL) instruction; nonstandard (or non-existent) entrance requirements and examinations;
lack of objective skill assessment during and upon completion of training and non-accredited online
distance education.

PVS recruitment of injured workers
L&I requires a school or training provider to have admission open to the general public; however,
some of the private schools that our workers attend most often have focused their recruitment solely
on injured workers. It appears that some PVS have promoted general and computer front-office job
training to VRCs as meeting special needs of injured and disabled workers. Some of these schools
offer bilingual instruction in Spanish, GED preparation, and offer a slower pace and less daily class
time tailored to a specific student. Entrance requirements for and the type of special services
provided to workers are not always clear. Extended length of a program is sometimes the only
offering based on a determination of special needs of the injured or disabled student’s abilities. This
approach is not consistent with many private schools, or with the public school approach. Most
schools rely on remedial preparation prior to a program, rather than adjusting the program length.
This is distinctly different from the approach at most public and many private schools, where the
curriculum and program length is set and a student qualifies for it or they do not. The potential
problems from these approaches include putting a worker into a program where they may not be
successful and the possibility of a school “accepting everyone” for financial gain. It is important to
note that most of the complaints and concerns about worker training that were identified during this
project are about one or more of the private schools that are most often attended by our workers.
Complaints about other private schools and public schools are much less frequent.

In-demand jobs
Choice of job goal may be restricted by availability of training as well as by the labor market. In rural
locations, training options can be more limited for all job goals. Distance learning (web-based
learning) is a relatively new and growing approach that may fill this gap for some.
Two job types, general office clerk and truck driving, provide examples of the options available for
popular “in demand” jobs. Truck driving requires a worker to obtain a specialized license. General
office work does not have that requirement. (See Appendix C: Career Bridge and Eligible Training
Provider (ETP) list; Figure 6, Career Bridge website information Trucking certificate.)
A worker looking at a commercial driver’s license (CDL) Class A trucking job may be comparing
different PVS programs with community college programs. CDL training is usually on-location
training. All CDL schools are licensed by DOL and the Workforce Board and their curriculum and
hours of training is approved by DOL. In contrast, online (distance learning) is a growing option for
some retraining programs such as general clerk or receptionist. There is no easy way to compare
13

 similar certificate programs at a community college, for an apprenticeship, at a small trade-oriented
vocational school or at a larger PVS. In addition, some trade schools, such as those with trucking
programs, include a higher standard of curriculum review by the Department of Licensing. Without
an easy means or singular tool or method to evaluate curriculum quality, program length, and cost of
tuition, choice of the right school may be merely a best guess rather than an informed choice.
Detailed information about currently existing resources to help workers make these determinations is
in Appendix C: Career Bridge and Eligible Training Provider (ETP) list.

Worker motivation and participation
Worker motivation and participation play an important role in successful training plan completion,
and both may be affected by the lack of tools for workers to evaluate training program options. Claim
review information shows expectations about schooling may change as a vocational plan progresses.
Many injured workers beginning vocational training show a high degree of interest and positive
expectations. Some injured workers reported altered expectations at the end of the process, even
when finding a new job. Some certificate programs offer active and often successful job placement
services, while others offer none.
In addition to worker motivation, worker understanding of training program expectations for
progress, attendance, and other factors key to successful participation is critical to successful
completion of training. These expectations are defined in statute. Since failure to abide by these rules
can result in suspension of benefits, a worker who does not understand the system and/or has
unaddressed barriers is at risk of training plan non-completion.

14

 The project
The Private Vocational Schools Collaborative Project began in February 2016 in response to
concerns about low completion and employment rates for injured workers who attend vocational
training. L&I collaborated with the Workforce Training and Education Coordinating Board
(Workforce Board) on the project to:
 Assess the effectiveness of private vocational schools in preparing injured workers to reenter the
job market
 Identify gaps in the retraining process
 Determine solutions to address retraining gaps
Research methodologies for this project included school visits to evaluate use of best practices, focus
groups, and review of 2015-2016 claim files with completed and uncompleted proposed plans.

Assessing the effectiveness of private vocational schools in preparing injured
workers to reenter the job market
As part of the Private Vocational Schools (PVS) Collaborative Project, L&I in conjunction with the
project advisory committee developed best practice guidelines for private vocational schools. Best
practices describe standards for policy, ethical management and administrative operations for postsecondary schools. The best practice guidelines shown in Figure 4, while not all-inclusive, represent
desirable best practices at certificate programs under consideration by prospective injured workers.
Some of these best practices are part of licensing standards and many are included in accreditation
standards. These best practice guidelines were used in the project as a starting point to assess the
effectiveness of private vocational schools.

15

 Figure 4: Private Vocational Schools Collaborative Best Practice Guidelines
Training program component

Best practices

Faculty qualifications

Faculty members are certified or licensed where required by law. Administrators meet minimum
qualifications.

Admissions/Institutional policies &
practices

Schools are open to the public. School admission criteria/policies are to admit only students capable of
benefit.

Ability to Benefit assessment





Entrance exams are specific to the type of industry certificate/program and evaluation of skills and
abilities.
School is required to document HS diploma or GED and use of admissions test in lieu of diploma.
Standard Ability to Benefit Exam (ABE) is used with third-party standards for non-high school
diploma/GED.

Industry or employer-based
curriculum for non-degree programs
(if offered)






Program evaluation: Includes a process for systematic and evidence-based evaluation.
Program organization and length: Curriculum is focused on occupational requirements.
Curriculum planning: Includes evidence-based process and external validation/defined standards.
Externships are offered in bona fide occupational settings and planned with criteria and timeline.

Student protection and success
standards







School infrastructure is appropriate to mission and regulatory requirements.
Student assessment and complaint processes are defined, and employment assistance and job
readiness assistance are provided.
Credit/degrees/certificates require documented achievement replicating higher education norms.
Student success defined. EX: through coach/mentor process and separate faculty/department focus.
School discloses standards via catalog, enrollment agreement, student progress updates, etc.

Student achievement and institutional
purpose





A published mission or purpose specific to achievement informs all aspects of institution.
Student educational achievement is assessed systematically with faculty involvement.
Completion rates are tracked and there is ongoing attention to retention and completion rates.

Learning outcomes and skill
attainment




Skill attainment and assessment of student progress are defined prior to the training start date.
Entrance exam is specific to the type of industry certification or program.

Distance education program standards
(on-line programs or schools)



School demonstrates distance education methodologies (equivalent to similar type programs) for
management, administrative, capacity, equipment, facilities, technology, verification/privacy, and
employment outcomes.
Pre-admission and post admission standards are defined.


Standards for addressing Limited
English Proficiency (LEP) students







Available employment and student
completion data/information





School has LEP standards and tracks LEP student success.
Instruction is conducted primarily in English by a certified Teaching English to Speakers of Other
Languages (TESOL) instructor.
Students complete ESL in front-loaded courses prior to career-oriented training or integrated courses
with which ESL is taken concurrently.
Students enrolled in ESL courses are tested in English proficiency prior to start and end of the
program.
A qualified third-party test administrator administers tests. Normed tests are used (Test of English as
Foreign Language or (TOEFL) or Test of Written English (TWE)). Results are measured.
Accredited (only) student outcomes meet federal requirements at certificate level.
School discloses graduation and graduate employment rates for each program.
Licensed school programs meet Eligible Training Provider (ETP) requirements; OR School
publishes student data and meets L&I WAC requirements for job placement.

16

 School visits – a tale of four schools
To assess PVS effectiveness, L&I staff visited 15 private vocational schools around the state to
consider each school’s use of best practices. L&I found varying degrees of best practices at the
schools visited. Four PVS are highlighted below:
A small Commission on Accreditation of Rehabilitation Facilities (CARF) non-profit school in
Renton that offers forklift and other warehouse industry training focuses on a small student body and
individually tailored hands-on and classroom training. CARF accreditation standards help ensure
participation and foster motivation of students. The school’s primary instructor was in the warehouse
business locally for a number of years, and taught standards and safety as part of both classroom and
one-on-one instruction. Facilities were small but professional.
A small PVS in Vancouver, although not currently taking private pay students, offers training in
soldering with robust job placement services. The school has small but professional facilities with a
classroom geared to hands-on instruction. Staff met one student who was visually impaired and
proud of his skills in building circuit boards and his success in the classroom; the instructor discussed
how he modified the way he presented information in order to foster this student’s success. This
school has a separate website for employers highlighting its graduates. Due to trade requirements, all
graduates must pass skill-based exams for eventual certification.
A PVS in the process of being licensed in Kennewick is shifting its focus from continuing education
of Hanford workers to training injured workers in office skills, which does not require certification
for specific trade-based skills for graduation. The owner is building upon Information Technology
certifications and knowledge of local employers to design a curriculum that uses grades and exams
rather than a pass/fail approach based on time spent with an instructor.
One school uses primarily distance learning to teach a number of programs. It provides a “full
package” for accessing online instruction from a worker’s home, including loan of a computer and
internet access for each student. Student course work is self-paced and review is pass/fail. Online
instructor time is monitored by the school and student time spent on any given day is flexible. This
PVS showed the highest volume of worker attendance in 2015 of any other PVS (147 L&I students)
and of most similar community college certificate programs in general office and medical office.
This school declared its mission as working with the most difficult-to-place students. However, they
can provide no evidence of where their graduates are going to work. Program completion rates are
high; however, job placement rates are not tracked. The school has reported up to a 95 percent
completion rate.
These four schools are examples of the significant variance in the type and format of retraining, as
well as the adoption (or lack of) of best practices. Of the 15 schools visited, some offer an industrybased curriculum that includes hands-on and classroom instruction, flexible ample one-on-one
instruction, and robust assistance with job placement. PVS standards vary widely, and many are not
as clear or consistent as the four schools described.

17

 Of the 15 schools visited, at least three did not have standard entrance exams and appeared not to
turn away students for any reason. Standards were difficult to determine and student progress
depended on instructor evaluations and the amount of time spent by the student. These schools
emphasized worker motivation as the key to success. Some programs included no grades and a
pass/fail approach, with most students graduating. Schools with students attending distance education
programs appeared to vary widely in educational standards, models and offerings. Accredited
distance learning programs appeared to utilize higher standards for student admittance. Some PVS
offered ESL incorporated into the vocational training, but did not have certified ESL instructors.
Only one PVS was addressing this issue with intent to design a certified ESL program in the near
future. Another PVS used a bilingual instructor and a software package for learning Spanish that can
be purchased by the public. Job placement services ranged from robust to informal to none.

Identifying customer expectations
A 2013 research article by University of Washington (UW) researchers indicated that workers had
significantly higher hopes at the start of vocational planning than at the end of vocational training.
One reason for this dissatisfaction may be that programs for available postsecondary education, once
started, do not meet initial expectations. This may be due, in part, to a lack of worker knowledge
about the differences in training programs.
Two L&I Vocational Service Specialists (VSS) at WorkSource were interviewed about their
guidance for injured workers regarding PVS. One counselor said she routinely asks a customer to call
prospective employers regarding the desired job goal and ask employers about their confidence in a
particular certificate, whether from a community college or PVS. It is not clear whether this is a
standard practice with most vocational counselors.
The findings and recommendations from the University of Washington research are consistent with
some of the findings and recommendations of this project. The UW researchers’ suggestions for
addressing issues related to the knowledge gap are:
 Provide more training choices and more worker input into training goals to ensure a better fit
with the worker’s experience and abilities.
 Listen to and respect a worker’s goals, interests and limitations.
 Provide more help with job placement, reentry skills, and return to work.

Focus groups – Stakeholder perceptions
To gain perspective on worker retraining from a broad variety of stakeholders, L&I gathered
customer input. Focus group participants included workers’ attorneys, vocational counselors, claim
managers, vocational services counselors, and audit and dispute resolution staff. All focus groups
shared similar key messages, which are reflected in the following summary of feedback:
What’s working?
 Some schools have strong graduation-to-job transition rates and resources.

18

  Certificates from PVS that partner with local employers to identify desirable skills are seen as



valuable by employers in the labor market.
PVS that offer job counseling, placement help and resources for oversight of skills progression
and job placement are viewed more positively.
PVS that are smaller can offer greater program flexibility or tailor a program to a specific injured
worker/student’s needs.

What’s not working?
 PVS that “graduate” and simply pass students without validation of attainment of proper skills
and have low job placement rates do not work well for student success.
 Schools whose curriculum is not aligned with (local) industry needs have low job placement
rates.
 PVS that provide no information or access to job placement rates for graduates are considered a
problem.
 We have no way to know what skills are being taught prior to a worker taking a course, and no
way to determine what skills a worker has acquired after graduation.
 Schools with income primarily from L&I, those with tuition that may be viewed as excessive
tuition, and those that appear to focus on profit rather than student success received negative
feedback.
 Distance learning (online course work) had both positive and negative feedback. There was
agreement that these schools work better for some students but not for others.
 Schools that did not provide adequate information about quality standards for distance learning
programs were considered troublesome.
 Coursework identified as ESL that does not meet ESL standards
 Lack of standard entrance examinations.
What should the future look like (solutions)?
 Focus on return to work outcomes in addition to plan completion.
 Engage injured workers in an entire step-by-step process, including: 1) identification of desired
skills, 2) identification of strengths, and 3) early resume and job search activities, as well as at the
end of the training plan. Include choice of school or program in this process.
 Offer VRC job placement assistance upon completion of the training plan in coordination with
the school or training program.
 Data-track PVS for job placement and training plan completion rates. If an ETP list is made
mandatory, make sure there are enough choices available to all injured workers.
 Provide more targeted focus in the vocational retraining system tailored to injured worker
needs, especially for those with barriers such as LEP or psychological barriers.

19

 

Provide coaching in soft skills, and resources focused on job search and job placement. Soft
skills include instruction in job readiness including dressing for the job, appropriate email
communication, varied workplace culture expectations, and time management.20

The focus groups consisting of workers’ attorneys agreed that a pension for an injured worker often
equates to a psychological setback and lost opportunity. Although it is in the best interest of most
workers to return to skilled employment, delays in training, stopping and starting a different program,
incomplete understanding of available choices and assessment of student need and other missed
opportunities affect motivation. VRCs and claim management staff confirmed these messages. VRCs
added that some PVS offer easier access and provide easier methods of communication with
instructors for lower academic profile students.
VRCs and claims staff were concerned about:
 lack of standards for ability to benefit assessments and/or entrance exams done by the schools,
 lack of standard markers of success, and
 ESL classes/training not offered by a certified ESL instructor or at an accredited ESL program.
Workers’ attorneys echoed these same concerns. Some PVS said that they want to help workers with
multiple barriers to workforce reentry, but were concerned that their school would be blamed if a
student did not succeed.
Other feedback indicated that a “cookie cutter” or “one size fits all” approach hampers success.
Stakeholders recognized the need to keep what works for most in the system while also addressing
the needs of some workers with multiple barriers to reentering the workforce.

Review of injured worker claims
Claim file review was done on proposed vocational plans to gather more information about barriers
to reentering the workforce. Specific examples of problems with educational quality were found at a
number of schools for injured workers with multiple barriers to workforce reentry. These student
barriers, which may not have been addressed fully at some schools, included limited English
proficiency and literacy issues. These issues in particular may have added to students’ fears or
affected students’ ability to pass entrance exams such as those used at community colleges. Standard
exams are used in all accredited schools to assess math and verbal/written literacy at or below the 9th
grade and 12th grade levels. Students who do not pass these exams are first required to take remedial
education classes for no credit before progressing to a certificate level or degree level program of
study. These workers often selected a PVS that offered a nontraditional classroom, hands-on
learning, and one-on-one instructor time and no standard entrance exam. Programs that were less
than full time and distance learning programs were popular.
A second type of case file review was done on state fund claims from 2012-2015 with both
completed and non-completed vocational plans. This review used a methodology similar to the one
20

Private Vocational Schools Collaborative Project Focus Group notes, November 2016.

20

 used in the 2011 claim review study for consistency. It found similar issues around lack of entrance
exams and potential student need for adult basic education, LEP, as well as issues with lower
standards for non-accredited distance learning. This review included a sample of successfully
completed plans for comparison, with a particular focus on school-related issues including grades,
attendance, and access to courses.
Findings revealed that workers who had multiple barriers to reentry to the workforce as well as
residual effects from their industrial injury faced specific challenges with education. Multiple barriers
might include LEP, lack of a high school diploma or GED, over 10 years since their last formal
schooling, literacy issues below an 8th grade level in writing, lack of basic computer or math skills,
opioid use, a psychological diagnosis, or a singular work history in the heavier trades. Many of these
workers chose a PVS over community college. The lack of standard entrance exams and information
on job placement and training completion rates when evaluating a PVS certificate program remains
an additional barrier to all.21

Determining solutions to retraining gaps
L&I used the information gathered from school visits to assess best practices use, focus group
feedback, and review of injured workers’ claims to identify the causes of low training plan
completion and return to work rates.
Information gathered during this project indicates that:
 Lack of injured worker access to information about training programs’ completion rates and job
placement rates hinders informed choice, which ultimately contributes to lack of motivation. The
ETP list could serve as a measure of quality to help injured workers evaluate which schools and
programs have the best chance of leading to a desired job.
 A worker may choose a job goal without a full understanding of quality training options
available. Adopting and implementing use of the best practice guidelines for PVS that were
developed as part of this project could provide workers and VRCs with a systematic method to
compare options and evaluate quality.
 Workers with multiple barriers to reentering the workforce, as well as residual effects from their
industrial injury, face specific challenges with education. Piloted use of a Multiple Barriers (MB)
list when evaluating injured workers could be done as part of a pilot project involving interested
vocational staff, VRCs and schools. The pilot would also incorporate use of psychosocial
assessment to determine where the worker is at in their perceptions of school success and ways of
addressing barriers that have surfaced. Each worker with multiple barriers should be matched to
the best school or program following Best Practices Guidelines.

21

Private Vocational Schools Collaborative project 2nd Set of Eyes and Vocational Plans Claim File reviews and
2012-2015 Completed and Non-Completed Vocational Plans Claim File Reviews. Data Source: L&I Research and Data Services.

21

 Recommendations
L&I should address the lack of a simple measure of quality for certificate programs and require the
use of Best Practices guidelines and the ETP list. If a program is not on the ETP list with documented
completion and employment data, the VRC should explore a program’s best practices based on
worker need with particular emphasis on job and completion rate data and job placement services. By
doing so, L&I will align itself with other federal and state standards. L&I should also continue to
refer to the Workforce Board schools and programs that are not licensed but should be licensed.
In addition, we need more information and a systematic way to identify workers with multiple
barriers to reentering the workforce. These workers should attend training programs with higher
standards than those currently required at non-accredited schools, including accredited courses or
instructors for ESL, accredited distance learning, and normed ability to benefit assessments or
entrance exams.
These recommendations can help ensure that injured workers are receiving quality education that
leads to a job.

Next steps
It is essential to shift the definition of training success from a focus on plan completion alone to
include data on completion coupled with finding a job. Specific recommended actions include:

Improve informed choice for workers
Lack of access to job and completion rates hinders informed choice. To help injured workers
evaluate which schools & programs have the best chance of leading to a desired job, L&I should
require use of the ETP list by vocational counselors as a baseline proxy measure of quality.

Adopt best practice guidelines
A worker may choose a job goal without a full understanding of quality training options available. To
provide workers and VRCs with a systematic method to compare options and evaluate quality, L&I
should adopt best practice guidelines to include consultation with WorkSource.

Continually assess use of best practices
A commitment to using best practices is a commitment to using all the knowledge and technology at
one's disposal to ensure success. In addition to ensuring that licensed schools that train L&I workers
adopt best practices, L&I should evaluate best practices at unlicensed and non-accredited vendors
applying to train injured workers by:

22

  Updating criteria for unlicensed or non-accredited schools to be consistent with best practices


when these vendors reapply every two years.
Continuing to refer to the Workforce Board those schools and programs that are not licensed but
should be licensed.

Address workers with multiple barriers to reentering the workforce
Workers with multiple barriers to re-entry to the workforce, as well as residual effects from their
industrial injury, face specific challenges with education. Multiple barriers might include LEP, lack
of a high school diploma or GED, opioid use, over 10 years since their last formal schooling, literacy
issues below an 9th grade level in writing, lack of basic computer or math skills, a psychological
diagnosis, or a singular work history in the heavier trades.
VRCs assess each worker’s strengths and needs, but should pair this assessment with standard
markers of quality in certificate programs. Some workers with multiple barriers to reentering the
workforce need higher standards for ESL, ability to benefit exams and school entrance requirements,
and distance learning. L&I should pilot use of a barriers list when evaluating injured workers.
L&I should require accredited ESL and standard ability to benefit/ entrance exams for injured
workers, especially those demonstrating student need in the area of limited English proficiency and
adult education. Vocational counselors should more fully evaluate non-accredited online or distance
learning programs for students with multiple barriers to ensure student needs are fully addressed. A
pilot project involving interested vocational staff, VRCs, and schools should be implemented to
address student need for workers with additional barriers.

23

 Conclusion
This project has identified a number of issues that can interfere with a worker being successfully
retrained and job ready. We recommend that a system be developed that requires all private
vocational schools and all unlicensed or non-accredited programs that work with L&I to meet certain
best practices and data reporting requirements. We further recommend the identification of effective
(evidence based) practices when identifying and addressing a worker’s abilities, needs and potential
barriers to retraining. Finally, our system needs a better method for evaluation of training options that
will lead to gainful employment.

24

 Appendix A: Educational Standards for
Schools
Accreditation
The Higher Education Opportunity Act specifically protects students against poor quality education:
SEC. 123 Diploma Mills
(1) Prevent, identify, and prosecute diploma mills; and
(2) Broadly disseminate to the public information about diploma mills, and resources to identify diploma
mills.
SEC 103 ADDITIONAL DEFINIONS
(20) The term “diploma mill” means an entity that
(A)(i) offers, for a fee, degrees, diplomas, or certificates, that may be used to represent to the general public that the
individual possessing such a degree, diploma, or certificate has completed a program of postsecondary education or
training; and (ii) requires such individual to complete little or no education or coursework to obtain such degree,
diploma or certificate; and
(B) lacks accreditation by an accrediting agency or association that is recognized as an accrediting agency or…22

Accreditation upholds education standards per requirements of the 2008 Higher Education
Opportunity Act. Accreditation is required for most degree-granting schools, and is done by regional
or national accrediting bodies recognized by the U.S. Department of Education. Schools that offer
degrees but do not choose accreditation are not eligible for federal aid, including student loans. Some
non-degree granting, licensed schools can receive specialized accreditation from nationally
recognized accrediting bodies designed around professional organizations. Registered nursing is one
example of specialized accreditation.
The accreditation process encourages schools to become stronger institutions by setting and
following standards of educational quality, i.e., “best practices.” The accreditation process is costly.
Implementation may be challenging, as shown by the 2016 decertification of Accrediting Council for
Independent Colleges and Schools (ACSIC) and subsequent closure of ITT Technical Institute in
many states.
The Washington Student Achievement Council (WSAC) enforces accreditation at the state and
college level, concentrating on student success. WSAC partners with the Workforce Training and
Education Coordinating Board (WTECB) on accreditation for training offered at public and private
degree-granting schools.

Licensing
Licensed schools offer only certificate programs and are required to follow standards for policy,
ethical management, and administrative operations at the post-secondary level. The goal of the state

22

Higher Education Opportunity Act of 1965 amended 2008, (Public Law 110-315).

25

 licensing process is quality education and consumer protection for the prospective student. The
majority of PVS are licensed schools. Licensing PVS at the state level reflects the same intent as U.S.
Department of Education accreditation of degree-granting public and private colleges and
universities at the federal level.
The regulatory process for licensed schools is similar to, but does not mirror, the accreditation
process for degree-granting schools. Both the accreditation process and the state licensing process set
forth essential standards of quality against which a school and specific course or program of study is
measured. The licensing process guarantees schools meet standards for financial stability, adequate
and qualified staffing, and quality of career-focused programs.
The Workforce Board’s Consumer Protection Unit regulates licensing of private schools in our state,
with some exceptions. The unit licenses about 330 private schools, collects student data annually,
investigates student complaints, and administers Tuition Recovery Trust Fund (TRTF). The
Consumer Protection Unit also contracts with the Department of Veteran’s Affairs as a State
Authorizing Agency (SAA).
Because some industries require certification or a license for a profession, such as home inspector,
other state agencies and federal regulations may mandate additional standards. The Department of
Licensing (DOL) regulates licenses for truck drivers and for cosmetologists. The Department of
Social and Health Services (DSHS) regulates licenses for certified nursing assistants. Other examples
include acupuncture, massage therapy, emergency medical technician, medical assistant, animal
massage, commercial truck driving, long-term care and maritime programs. These programs must
meet requirements of agencies such as the Department of Health, DOL, DSHS, and Department of
Homeland Security.

Certification
Some public and private degree-granting institutions offer certificate programs, which certify that a
person has received specific education or has passed a series of tests related to a specific occupation.
Some of these programs require the graduate to obtain a license or certificate to work in the trade or
profession and others do not. Community colleges offer many certificate programs as well as
associate degrees.
There is no one standard performance measure required for certificate-level programs. Although
licensed schools are required annually to submit data on all students as part of the licensing process,
program performance data is only available for schools with programs that are on the voluntary
Eligible Training Provider (ETP) list. Licensed schools are not required to make job and completion
data available to prospective students. The ETP list provides independent verification of employment
and earnings, and completion rates, for programs that receive federal training dollars, or state training
dollars through the Employment Security Department’s Training Benefits program.

26

 Appendix B: Workforce Training and
Education Coordinating Board
The Workforce Training and Coordinating Board (Workforce Board)
The Workforce Training and Education Coordinating Board (Workforce Board) is a board made up
of three employer representatives, three labor representatives, and three state agency representatives,
along with major service providers and specific non-voting members. The Workforce Board was
created in 1991, replacing four state boards that supervised the state’s tangled training system. The
Workforce Board replaced these boards and created a coordinated and more accountable workforce
system. The Board’s strategic plan Talent and Prosperity for All, or TAP, details the state’s
opportunities and workforce objectives. The Board’s performance reports enforce strict
accountability measures that go beyond federal requirements, ensuring the state’s education and
training programs receive an objective evaluation, meet Washington’s high performance goals, and
offer a return on investment for taxpayers. The Workforce Board is committed to sustaining
Washington’s economic vitality through a highly skilled workforce. The board oversees a workforce
development system including:
 16 workforce programs receiving almost a billion dollars annually in state and federal funds.
The Workforce Board is Washington’s leading policy advisor for issues related to the state’s
workforce. State law makes clear that the Workforce Board is “the hub” of the workforce training
system. The Workforce Board is a small agency with 20-plus full-time staff, focused largely on
policy and research, which often guides other key agencies and local boards to take action.
The Workforce Board partners with seven state agencies in the oversight of quality post-secondary
education: Employment Security Department (ESD), Washington Student Achievement Council,
State Board for Community and Technical Colleges, DSHS – DVR, Department of Services for the
Blind, Department of Commerce and Office of the Superintendent of Public Instruction. Part of the
Workforce Board’s mission is to bridge the gap between skills of graduating students and the skills
employers want.

Entry point for customers – WorkSource
WorkSource is the “one stop” for direct customer service for Washington’s jobseekers and employers
seeking to hire skilled workers. WorkSource has a robust website and offers career planning tools
including a statewide occupation search, direct links to job opportunities including in-demand jobs,
labor market information, help with resumes and interviews, job search skills, tutorials, hiring events,
and more. WorkSource employment specialists assist consumers with finding a job and assist some
consumers, who quality for federally funded programs, with post-secondary education. Injured
workers already have access to WorkSource assistance at one-stop service locations and the
worksource.wa.com website, and through contracted L&I VRCs on location at regional WorkSource
centers.
27

 Four L&I vocational services staff are located at local WorkSource offices and two ESD
WorkSource return-to-work specialists are situated within Claims Administration. Two L&I
vocational services staff at WorkSource were interviewed about their guidance for injured workers
regarding PVS. One counselor said she routinely asks a customer to call prospective employers
regarding the desired job goal and ask about their confidence in a particular certificate, whether from
a community college or PVS.

Workforce Innovation and Opportunity Act (WIOA)
Many Workforce Board workforce development policies are influenced by the federal Workforce
Innovation and Opportunity Act (WIOA). At the federal and state level, WIOA defines a set of
programs and money available for employment services, job placement, and education and
populations. These populations include unemployed and dislocated workers, low income youth, low
income job seekers over 18 years old, foreign trade-affected workers, low income adults who are
recipients for Temporary Assistance for Needy Families (TANF), workers with limited literacy
skills, or workers needing English language instruction. Access to WIOA programs can be found at
the regional WorkSource offices in our state. An online directory of agencies and workforce services,
including those provided under WIOA, is located on the Workforce Board website.23
The federal baseline on job and completion rates for WIOA-funded training centers is found in the
Eligible Training Provider (ETP) list (Appendix C). The ETP criteria for a post-secondary certificate
or an accredited college certificate program is 50 percent completion and 30 percent employment for
completers over a three-year period.

Talent and Prosperity for All (TAP)
In October 2016, The U.S. Department of Education and Department of Labor formally approved
Washington state’s workforce plan, “Talent and Prosperity for All” (TAP). The TAP strategic plan
focuses on best practices for any prospective student seeking training to enter or re-enter the
workforce. The TAP mission is specific to WIOA.
The TAP plan concentrates on Washington’s workforce with the intent to help more people find and
keep jobs and close the skill gap for employers. The plan includes implementation committees for
five areas, including Integrated Service Delivery, Business Engagement, Common Intake Process,
Performance Accountability/Data Sharing, Professional Development, and Barriers and
Accessibility.
As citizens attempting to re-enter the workforce, disabled injured workers are included in the TAP
mission, although funding for vocational training is not WIOA-based. L&I’s mission is congruent
with the WIOA mission of connecting injured workers with the skills they need to be successful in
obtaining a new job and building a career as well as connecting employers with the skilled workers
that they need to stay competitive in our state. Some injured workers face similar barriers to
workforce reentry, as do some of the identified populations under the Barriers and Accessibility
23

Workforce Training and Education Coordinating Board, Washington Workforce Development Services Matrix.

28

 Solutions section of the plan. The Barriers and Accessibility focus is to identify and remove a wide
variety of barriers to access, including economic, geographic, physical, mental, and behavioral health
barriers.

WTECB consumer protections for students
Students of non-degree granting schools, whether public or private, are protected by the WTECB’s
Consumer Protection Unit. This unit licenses and regulates private vocational schools and
administers a Tuition Recovery Trust Fund for schools that close. The unit provides orientation for
new schools and reviews school policies, enrollment agreements, catalogs, and other written
materials. Licenses must be renewed annually, and staff do an onsite monitoring visit to schools
every two years.24
WTECB also has a student complaint process to review unfair business practices of private career
schools. Students are advised to attempt to resolve all complaints with the school first. For a student
making a formal complaint, tuition may be refunded for licensed private vocational schools violating
the principals below:
Unfair Business Practices
(1) The school failed to comply with the terms of your enrollment contract or agreement.
(2) The school falsely claimed that its educational program was approved by a particular industry or that successful
completion of its program would qualify you for admission to a labor union or similar organization or for the
receipt of a state license in any business, occupation, or profession.
(3) The school falsely represented that its credits were transferrable to an institution of higher education.
(4) The school misrepresented its size, location, facilities, equipment, faculty qualifications, or accreditation.
(5) The school stated that it was approved, recommended, or endorsed by the state of Washington or the
Workforce Board.
(6) The school provided testimonials, endorsements, or other information that misled you regarding its current
practices, current conditions for employment, or probable earnings in the occupation for which you trained.
(7) During the enrollment process, the school referred to its sales agents as counselors or advisors.
(8) The school made statements it knew or reasonably should have known were false, substantially inaccurate, or
misleading.
(9) The school engaged in false, deceptive, misleading or unfair advertising, sales, collection, credit, or other
business practices. 25

24

Workforce Training and Education Coordinating Board: http://wtb.wa.gov/WorkforceBoard.asp.
Workforce Training and Education Coordinating Board: http://www.wtb.wa.gov/PCS_Complaints.asp.

25

29

 Appendix C: Career Bridge and Eligible
Training Provider (ETP) List
Career Bridge
Career Bridge (careerbridge.wa.gov) is a free, state sponsored website, sponsored by the WTECB,
which connects students to over 6,300 programs of study. Information is available on in-demand
jobs, tuition rates, and length of school programs. Published performance measures are tied to the
Eligible Training Provider (ETP) list and are not required for all schools. Approximately 40 to 50
percent of the certificate programs listed on Career Bridge show performance measures. Some are
simply checked as meeting the federal baseline. Private vocational schools that submit annual student
data to the Consumer Protection Unit and elect to be on the ETP list will have their data evaluated for
performance.
All schools on Career Bridge must report annual student data. Not all data is published. The
Veteran’s Administration has separately tracked requirements. Reporting requirements vary.

 Community and technical colleges report only non-credit programs (credit programs data is






reported to partners and SBCTC, and data is sent directly from them to WTECB).
Public four-year colleges report only certificate programs (degree programs are reported through
ERDC and data is received from them).
All Workforce Board private career schools, both in state and out-of-state, report.
All Washington apprenticeship programs data is collected by L&I and received from them.
WSAC-approved accredited schools report all programs on Career Bridge.
Cosmetology schools report all programs on Career Bridge.26

The Career Bridge website is one source for comparing tuition and program length, but does not offer
information on all PVS’ programs’ completion rates and job placement rates. Many programs are too
small to have specific performance measures published. Those school’s programs are given a check
mark for the ETP list. Program quality is not measured. Licensed schools self-report tuition and
program length.
Figures 6 and 7 provide an example of the information available on Career Bridge for comparison of
training at various locations for trucking versus general office, accounting and medical office jobs.

26

http://www.careerbridge.wa.gov/

30

 Figure 5: Career Bridge website information - General office, accounting/bookkeeping
and medical office certificates
Big Bend Community College,

Program length

12 months (66 credits)

12 months (48 credits)

Medical
Office/Receptionist
Certificate
12 months (58 credits)

Estimated total tuition

$6781

$4932

$5,959.50

Moses Lake (Community College)

General Office/
Customer Service Certificate

Office Careers, Renton
(Private vocational school –

General Office/
Customer Service Certificate

Accounting/Bookkeeper
Certificate

Accounting/Bookkeeper
Certificate

Medical
Office/Receptionist
Certificate

Distance learning)
Program length

12 months

12 months

12 months

Estimated total tuition

$13,800

$13,950

$13,950

Spokane Community College
(Community college)

General Office/
Customer Service Certificate

Accounting/Bookkeeper
Certificate

Program length

18 months (97.5 credits)

18 months (90 credits –
AAS degree)

Estimated total tuition

$10,033.73

$9,261.90

Allied Training Systems, Spokane
(Private vocational school)

General Office/
Customer Service Certificate

Accounting/Bookkeeper
Certificate

Medical
Office/Receptionist
Certificate
9 months (42 credits)
$4,322.22
Medical
Office/Receptionist
Certificate

Program length

46 weeks (920 clock hours)

51 weeks (1,010 clock
hours)

57 weeks (1,140 clock
hours)

Estimated total tuition

$14,185

$15,505

$16,720

Perry Technical Institute, Yakima
(Private vocational/technical school)

General Office/
Customer Service Certificate

Accounting/Bookkeeper
Certificate

Medical
Office/Receptionist
Certificate

Program length

N/A

18 months (2,016 clock
hours – AAS degree)

12 months (1,344 clock
hours)

Estimated total tuition

N/A

$29,504.25 (includes
books/supplies)

$21,413 (includes
books/supplies)

Renton Technical College
(Community college)

General Office/
Customer Service Certificate

Accounting/Bookkeeper
Certificate

Medical
Office/Receptionist

Program length

12 months (73 credits)

12 months (64 credits)

Certificate
12 months (72 credits)

Estimated total tuition

$8011.75

$7,034.24

$7,902

Data Source: Career Bridge website: http://www.careerbridge.wa.gov/

31

 Figure 6: Career Bridge website information – Trucking certificate
Commercial Driver School, Auburn
(Private vocational school)

Trucking CDL Class A
Certificate

CDL Class B Dump
Truck Certificate

Heavy Equip Operator
Mechanic Certificate

Program length

6.5 weeks (260 clock hours)

76 clock hours

N/A

Estimated total tuition

$14,761

$7,271

Estimated clock hour/credit tuition

$56.77 per clock hour

$95.67 per clock hour

N/A
N/A

Bates Technical College, Tacoma
(Community college)

Trucking CDL Class A
Certificate

CDL Class B Dump
Truck Certificate

Heavy Equip Operator
Mechanic Certificate

Program length

6 months

N/A

12 months (106 credits)

Estimated total tuition

$5,877.93

N/A

$12,868.52 Include
books/fees

Estimated clock hour/credit tuition

$99.32 per credit hour plus

N/A

$99.32 per credit hour plus
$2,340.60 for books/fees

$2,232.55 for books/fees
West Coast Training, Kirkland
(Private vocational school)

Trucking CDL Class A
Certificate

CDL Class B Dump
Truck Certificate

Heavy Equip Operator
Mechanic Certificate

Program length

4 weeks (160 clock hours)

N/A

8 weeks (320 hours – H.E
Operator NCCR)

Estimated total tuition

$4,750

N/A

$14,000

$29.68 per clock hour

N/A

$34.75 per clock hour

Estimated clock hour/credit tuition
Walla Walla Community College
(Community college)

Trucking CDL Class A
Certificate

15 months (80 credits –
diesel technology)

$2,522.30
$114.65 per credit

$119.34 per credit

$114.65 per credit

2.5 months (22 credits)

Estimated total tuition
Estimated clock hour/credit tuition
(Private vocational school - Bilingual
instruction)

Heavy Equip Operator
Mechanic Certificate

10 weeks (22 credits –
truck driver training)
$1,717.32

Program length

GMC Training Institute, Grandview

CDL Class B Dump
Truck Certificate

Trucking CDL Class A
Certificate

CDL Class B Dump
Truck Certificate

$9,172
Heavy Equip Operator
Mechanic Certificate

Program length

10 weeks (160 hours)

7 days (53 hours)

N/A

Estimated total tuition

$7,200

$5,350

N/A

Estimated clock hour/credit tuition

$45 per clock hour

$10 per clock hour

N/A

H&R Elite Trucking, Sunnyside
(Private vocational school)

Trucking CDL Class A
Certificate

CDL Class B Dump
Truck Certificate

Heavy Equip Operator
Mechanic Certificate

Program length

4-5 weeks (160 hours)

4-5 weeks (160 hours)

N/A

Estimated total tuition

$4,090

$4,090

Estimated clock hour/credit tuition

$25.56 per clock hour

$25.56 per clock hour

N/A
N/A

Trans 360, Inc., Vancouver, WA
(Private vocational school)

Trucking CDL Class A
Certificate

CDL Class B Dump
Truck Certificate

Heavy Equip Operator
Mechanic Certificate

Program length

1 month (160 hour)s

6 days (48 hours)

N/A

Estimated total tuition

$4,800

$3,050 plus fees

Estimated clock hour/credit tuition

$30 per clock hour.

$63.54 per clock hour

N/A
N/A

Data Source: Career Bridge website: http://www.careerbridge.wa.gov/

32

 Eligible Training Provider (ETP) list

The Eligible Training Provider (ETP) list is a federal standard under the 1998 Workforce Investment
Act now modified as WIOA. Most accredited community college programs use the list, which is only
open to programs that provide data that meet a baseline of performance thresholds. Those programs
that meet those thresholds may receive federal training dollars through WIOA, or state training
dollars through the Training Benefits program overseen by the state’s Employment Security
DepartmentParticipation on the ETP list is voluntary for licensed schools, as well as all other schools
and colleges in our state.27
ETP-listed schools' programs must meet the Workforce Board’s threshold for rates of employment,
earnings and completion rates. The ETP list provides an independent verification of job and
completion rates based on Employment Security Department data.
In 2014, Governor Inlsee adopted the most recent ETP thresholds set by the Workforce Board to
determine training program eligibility. A program must be ETP-listed to be entitled to WIOA
funding (excluding apprenticeship programs), meaning it meets or exceeds each of the following
performance floors:
 Completion rate of 20 percent
 Employment rate of 50 percent
 Earning level of $3,943 in a calendar quarter
Failure to achieve any of the above performance floors will make a program ineligible for
Washington’s ETP list. In addition, a program must achieve the following on average over a multiyear period:
 Completion rate of 30 percent
 Employment rate of 65 percent
 Earnings level of $4,965 in a calendar quarter
Schools featured on Career Bridge do not need to be ETP-listed, including:
 Community and technical colleges
 Public and private four-year colleges and universities
 Private career schools
 Washington apprenticeship programs

27

Per WTECB source, the Workforce Board sets these performance thresholds, typically annually. They are not set by the federal
government directly. However, all states are required to maintain their own ETP lists and it is likely that there is a minimum federal
baseline. What is clear is that Washington education programs must meet Washington’s standards.

33

 Appendix D: Helpful Links
1.

Link to Workforce Training and Education Coordinating Board
http://www.wtb.wa.gov/WorkforceBoard.asp

2.

Link to Workforce Board Talent and Prosperity for All (TAP) strategic workforce plan:
http://www.wtb.wa.gov/WAWorkforcePlan.asp

3.

Link to Workforce Board Workforce Development System Poster:
http://www.wtb.wa.gov/Documents/Matrix2014_000.pdf

4.

Link to Workforce Board Private Career Schools and Consumer Protections:
http://www.wtb.wa.gov/pcs.asp
http://www.wtb.wa.gov/ChoosingASchool.asp

5.

Link to Workforce Board student complaint form:
http://www.wtb.wa.gov/PCS_Complaints.asp

6.

Link to Eligible Training Provider (ETP) list standards:
http://www.careerbridge.wa.gov/Page.aspx?cid=134

34