KYAE greatly appreciates KAACE’s concern for adult education policy; however, providers should always contact KYAE for policy interpretations, to ask programmatic questions or to express concerns. KYAE sets adult education policy in the Commonwealth and is the only organization that can provide official policy interpretations to providers.
KYAE is the only entity that has the authority to negotiate with the federal Office of Vocational and Adult Education (OVAE) in setting KYAE policy and procedures. On a national level, KYAE has and will continue to aggressively advocate for reasonable and workable adult education policies.
Over the past year as KYAE has negotiated a revised assessment policy with OVAE, we have passionately advocated a process that is in the best interest of students. KYAE believes strongly that instructors need flexibility to administer post-assessments in a manner that best meets student needs, and we forcefully advocated that position in discussions with OVAE. Because of our extensive work with OVAE, we successfully negotiated a process that allows instructors to make exceptions to the recommended timeframes, a provision absent in the initial discussions of the new national requirements.
KYAE recognizes that the timeframes are termed “recommended” and that test publishers may not consistently articulate the timeframes. Regardless of this, the timeframes have been adopted by OVAE, and all states have been told to comply. Kentucky’s adult education system receives $9 million annually in funding through the federal Workforce Investment Act, Title II, and it is our legal responsibility to fully comply with OVAE mandates. Many other states are working through these assessment policy issues, and OVAE is recommending Kentucky’s policy and exception process to other states as a model.
Please continue sending KYAE your questions and concerns regarding the assessment policy as we want to make sure all providers clearly understand the new provisions. When KYAE is aware of provider concerns, we can better communicate to the entire field. Providers can call Janet Hoover at (502) 573-5114, ext. 109, or e-mail her at Janet.Hoover@ky.gov.
The following are FAQs we have received so far.
Q: Do I have to place exception forms in folders of students who post-test before October 1, 2006?
A: No. The policy is effective October 1, 2006, and KYAE will make sure auditors are aware of the effective date.
Q: Is the copy of the exception form placed in a local program director file or forwarded to Frankfort?
A: A copy should be placed in the local program director file.
Q: Does KYAE realize most students will have exception forms in their folders?
A: KYAE is aware of this possibility. It is critical that providers accurately record and report all contact and attendance hours. Careful recording of all types of eligible hours will provide a more accurate accounting of student effort and will reveal a truer picture of student attendance and a better tally of hours between pre- and post-testing.
NRS defines contact and attendance hours 
as “hours of instruction or instructional activity the learner receives from the program. Instructional activity includes any program-sponsored activity designed to promote student learning in the program curriculum, such as classroom instruction, assessment, tutoring or participation in a learning lab. (Note: Time spent on assessment can be counted only if the assessment is designed to inform placement decisions, assess progress or inform instruction. Time used to take the GED test, for example, cannot be counted as instructional activity.)”