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#AskExcelinEd: What does Perkins V’s new Local Comprehensive Needs Assessment requirement mean for states?


• Melissa Canney

ExcelinEd’s new brief Perkins V Reauthorization: Opportunities, Challenges and Risks for States identifies eight shifts Perkins V makes that present critical decision points for states pursuing high-quality CTE programs. In today’s post, ExcelinEd’s Melissa Canney  examines the reauthorization’s new Local Comprehensive Needs Assessment requirement.


Perkins V contains a new requirement within the local recipient application for funds. This requirement—the Local Comprehensive Needs Assessment—must be included in each local application and updated at least every two years.

Perkins V sets forth the following five requirements for the Local Comprehensive Needs Assessment:

  • Evaluation of student performance by subgroup on Perkins core indicators.
  • Description of the Career and Technical Education (CTE) programs offered (size, scope, quality and alignment).
  • Evaluation of the progress toward implementing CTE programs and programs of study.
  • Description of recruitment, retention and training for CTE educators and support professionals.
  • Description of progress toward implementing equal access to CTE for all students.

Local recipients are also required to engage several groups of stakeholders in developing the assessment and on an ongoing basis to support cross-sector coordination.

New Opportunities

While local recipients are responsible for completing the Local Comprehensive Needs Assessment, this new requirement offers several opportunities for states.

  • States are given flexibility to set additional requirements for the contents of the local application, including the Local Comprehensive Needs Assessment. This provides states with the opportunity to customize these requirements to fit their unique contexts and visions for high-quality CTE programs. For example, states may consider setting guidelines for consistent data definitions when analyzing labor market and wage data to ensure CTE programs are aligned with in-demand fields or are requiring local recipients to set goals and measure progress toward benchmarks state-specific initiatives (such as a statewide postsecondary completion rate goals). States can also meaningfully integrate this ongoing evaluation with other local, regional and state strategic planning processes. This coordination could reduce possible duplication of effort within regions and districts.
  • The Local Comprehensive Needs Assessment also provides states with the opportunity to develop processes to share student outcome and workforce data with local recipients. States that provide consistent data to local recipients could increase the local efficiency of data collection and analysis and encourage outcomes-based program decision-making. States that choose to synthesize and provide data from multiple agencies to local recipients as part of this process may increase long-term efficiencies and alignment.
  • Finally, states have the option to require the inclusion of data beyond that required by Perkins V. Including other measures of student achievement and outcomes would allow the local needs assessment to address all issues related to college and career readiness. Additionally, it would leverage the stakeholder engagement requirements of the law to ensure that local and regional partners are informed and included in progress toward meeting their local and statewide goals.

New Challenges and Risks

While this new requirement seeks to engage more stakeholders in the local planning and evaluation process, it also places increased administrative responsibilities on already-stretched local recipients of Perkins funds. States that do not provide additional guidance on how to include relevant data and stakeholders in this process risk creating a situation that results in inconsistent quality of Local Comprehensive Needs Assessments across communities. These Local Comprehensive Needs Assessments may be compliant with Perkins V requirements, but they may not appropriately focus on labor market data and stakeholder engagement to drive student outcomes and align with the state’s overall goals. In other words, this could result in additional local administrative efforts that do not positively impact quality and equity in local CTE programs aligned to priority industry needs.

States also run the risk of foregoing an opportunity to truly align and integrate the comprehensive local needs assessment process into state and local strategic goals. A lack of alignment could result in a reporting system that may duplicate efforts across districts, stakeholders and regions. Additionally, states and local recipients that approach this as a process separate from other required plans risk perpetuating chasms between CTE and general education.

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About the author


Melissa Canney

Melissa@ExcelinEd.org

Melissa Canney is the Director of Innovation Policy at ExcelinEd. She previously served as the Executive Director of Divisional Operations and Communications in the Division of College, Career and Technical Education at the Tennessee Department of Education. Melissa’s experience in Tennessee included policy analysis and implementation, communication strategy development, grant management and data analysis related to college and career readiness. A Vermont native, Melissa earned a B.A in Sociology from Stanford University and an M.P.P. in Education from Vanderbilt’s Peabody College. She lives in Nashville, Tennessee with her dog Moxie.