Policy Recommendations

The seven recommendations below, on three tiers, aim to balance flexibility with the targeting necessary to support opportunity youth. They should not be seen as an endorsement of block grants, as block-granting this funding would enable flexibility that might direct resources away from disconnected youth. Block grants do not appropriately balance flexibility with ensuring funding gets where it needs to go. The flexibility P3 seeks to allow is meant to make it easier to serve opportunity youth, not harder to get the necessary resources for them. Block-granting a program tends to lead to fewer resources overall. For example, a 2017 proposal to convert the Supplemental Nutrition Assistance Program into a block grant would have also cut 30 percent of its funding.¹ Furthermore, block grants do not allow funding to respond to economic indicators. If the need increases in a region, the resources do not match it.

Clarify allowable uses of federal dollars.

Our conversations with staff at P3 sites revealed confusion about how federal funding streams can and cannot be spent. Fear of noncompliance even led some site staff to impose restrictions not required by the federal government. If practitioners had a clearer understanding of flexibilities and waivers available under regular practice outside of P3, it could eliminate some of the barriers they face in serving opportunity youth and improve the delivery of those programs.

Myth-busting from federal agencies could help provide this clarity. We focus on P3 in this brief but believe this would benefit all career pathways programs. We suggest regularly releasing requests for information to solicit examples of challenges and questions from practitioners. Agencies can then issue guidance that speaks to common misconceptions and provides specific, and, if possible, real-world examples of how other sites use their federal dollars. Guidance should specifically address the flexibilities that require a waiver and those that programs can simply enact on their own. Programs also need clarity about which requirements come from the federal government and which are imposed by their state departments. Joint guidance issued by agencies is especially valuable to practitioners who receive funding from more than one federal department. Supplemental webinars through technical assistance platforms like DOL’s WorkforceGPS could reinforce messaging provided in guidance.

Maximizing federal investments requires a steady stream of support and guidance from the administering agencies, not just one-off efforts. Without continuous technical assistance, federal dollars are underutilized, but agencies do not always have the capacity to provide such hands-on support. Increased funding from Congress to boost federal technical assistance capacity could ensure funding is used more efficiently and effectively to serve youth.

Update the application solicitations.

Include real-world examples of how sites have used P3 flexibilities and examples of how P3 can support systems change. One reason sites struggle to submit strong applications for P3 is a lack of clarity about the available options. Specific examples of how other sites have used P3 can help spark ideas.

The government has already taken productive steps in this direction. The Federal Register notices soliciting applications include hypothetical examples of how P3 can be used, which has been a helpful practice for prospective applicants. For example, in 2021, one of the examples discussed waivers to include undocumented college students in TRIO programs, which prompted California colleges and universities to submit an application for that flexibility. Oregon postsecondary institutions followed suit the next year. (Both received P3 authority as single-agency pilots through ED.² In March 2025, the Trump administration revoked the pilots’ TRIO waivers.³) And since 2019, the notices have included a link to previously approved waivers, though the list has not been updated since 2018.

The government should build on this effort and provide real examples of how sites have (successfully) used the P3 authority. It should also update the list of previously approved waivers as new ones are approved and continue to include this list in application solicitations.

Clarify the goals.

Though one of the core goals of P3 was to promote systems change, most of the P3 interventions in the first three rounds aimed to improve service delivery for youth populations. The systems change goal is not clear in the P3 application solicitation, since the hypothetical examples of P3 used are focused on combining multiple federal funding streams to run programs for opportunity youth. They do not speak directly to how P3 can support collaboration, alignment, or partnerships across systems through strategies like shared data systems or collaborative governance.

If the government would like to encourage more systems change efforts through P3, it needs to highlight examples, hypothetical or not, of how to do so, and add metrics that would measure the success of such efforts. The interest from California and Oregon in response to the TRIO example shows that practitioners will take cues from the options provided in the application solicitation. P3 may have lost some of its appeal without implementation grants, but there is still an appetite for innovative ideas. Proposing realistic, inexpensive ways P3 can support systems change, and concrete ways this change could be measured, could entice prospective applicants to submit proposals to do just that and provide the evidence needed to scale up successful innovation.

The results from Los Angeles and Broward County suggest that, with the right enabling conditions in place, P3 can support both programmatic flexibility and systems change. For P3 to provide this dual support to all sites—not just those that have already begun systems change work—several key aspects of P3’s design and implementation need to be adjusted.

Codify P3 as a competitive grant program.

Include funding for planning, implementation, evaluation, and federal agency support. P3 authority is provided each year through the appropriations bill, which places it in a precarious position for several reasons. First, there is no way to predict if Congress will simply choose to exclude P3 from this bill in any given year, in which case the P3 authority would cease. And because the P3 authority is tied to the use of a particular year’s appropriation, the flexibilities for approved pilot sites are effective only for the period during which the appropriation could be spent, which limits the time in which sites can implement their P3 proposals. The appropriations process also worsens this time crunch: Appropriations bills are often pushed off further in the year as Congress increasingly relies on continuing resolutions to fund the government and avoid a shutdown. This forces agencies to run behind in implementing P3, starting the application process under one year’s appropriation and designating pilots under the next year’s appropriation.

Creating a permanent P3 authority would lend the program stability and provide sites with longer implementation periods. Funding for P3 could be generated by setting aside a small percentage of the money appropriated for the WIOA Youth Program, the Carl D. Perkins Career and Technical Education Act, and/or a youth-serving program administered by HHS, such as the Runaway and Homeless Youth Program. This funding structure would give each agency a stake in P3’s success and help boost buy-in at federal agencies. If Congress sets a clear expectation that it wants agencies to collaborate, it would have a license to grant waivers that some have hesitated to approve.

A codified P3 program should include three elements:

1. Implementation and evaluation grants. The slowdown in P3 applications, which coincided with the elimination of grant funding for P3 sites, reflects the fact that sites need money to do this work. Coordinating across organizations and systems is challenging and time-consuming. Funding not only encourages sites to apply but also allows them to actually implement P3.

Reinstating the grants to support both implementation and evaluation would attract more applicants and revive the government's ability to learn how well P3 works. We recommend adjusting the evaluation measures to include outcomes focused on systems change and alignment to encourage sites to build that work into their P3 proposals.

2. Planning grants. These should focus on supporting systems change and technical assistance to make the most of the time to plan. Mathematica found that sites that planned before P3 were the most successful at incorporating systems change efforts into their P3 work. We recommend funding planning grants and requiring that all P3 sites engage in a planning period before implementation.

Planning grants and individualized technical assistance from federal agencies would provide three key benefits. First, partners from across different systems could align around a common vision and goal for the P3 work before implementing it. This would provide all sites with the preplanning opportunity critical to P3’s success in Los Angeles and Broward County. Second, affording time and space to ask questions and get comfortable with P3’s flexibility would improve buy-in among site partners, increasing the likelihood of the intervention’s effective implementation. Third, sites would have the opportunity to receive feedback on and refine their P3 plans. Individualized support for sites around waiver selection and the systems-changes aspect of P3 would foster strong, innovative, and systems-change-oriented P3 plans.

3. Technical assistance. Though there were 14 pilot sites during the first three rounds of P3, the technical assistance was mainly for evaluation support. There was no formal, consistent TA program for the pilot sites as a cohort and few opportunities for them to learn from one another.

We recommend a more structured, cohort-based technical assistance model, including peer learning, site visits, and in-person convenings with federal staff. Peer-learning opportunities would allow site staff to learn how counterparts have taken advantage of P3 flexibilities, how those approaches could be applied to their own contexts, and how to tackle common barriers. Site visits to successful current or former P3 sites or localities that have done strong systems alignment work would offer a similar benefit. Pilot site staff told us that one of the most valuable aspects of their P3 experience was meeting with and asking questions of federal staff from multiple agencies at a convening in Washington, DC. Bringing back these opportunities for firsthand observation could boost buy-in from sites.

Broaden the opportunity youth definition.

Because the majority of waivers requested and approved were surrounding WIOA Youth, we recommend a broader definition of opportunity youth, like that proposed in the Stronger Workforce for America Act.⁴ This WIOA reauthorization legislation would replace “out-of-school youth” with “opportunity youth,” including youth experiencing homelessness and youth in foster care, regardless of school enrollment status.

Create state-level systems-change grants.

The challenge of aligning workforce, education, and human services systems could be more efficiently addressed at the state level rather than city by city. With resources and support, states could, for example, work to create or improve longitudinal data systems that providers across the state could access to support career pathways. This would make it easier for local organizations to work together, whether or not they have P3 authority.

Coordinate timelines and performance indicators.

For education and workforce systems at the state and local levels to coordinate most effectively, the legislation that governs these at the federal level should be more aligned. Ensuring that planning timelines line up and performance metrics work together will allow the WIOA and Perkins systems (and actors within them) a better chance at coordinating work streams and improving service delivery.