Source + trust record
Source checked as of September 18, 2026. Primary authority: USDOL TEGL 07-18, Change 1 and California’s WSD24-16.
Check result: TEGL 07-18, Change 1 remains active continuing guidance. It requires states to maintain data-validation procedures and recurring validation of 25 jointly required data elements using allowable source documentation. California operationalizes that framework through its own validation and documentation guidance and may impose additional documentation requirements. This AI-assisted brief does not receive human legal or compliance review. Official sources control.
The federal quality-control system behind California’s WIOA data validation
TEGL 07-18, Change 1 requires states to treat data validation as an internal-control system, not a once-a-year file check. It establishes written procedures, recurring reviews, staff training, monitoring, correction of errors, and source-document validation for 25 common WIOA data elements. California implements that federal framework through its own statewide validation process.
🚩 Statewide Action Alert. California Local Areas should treat source documentation and correction of reportable WIOA data as ongoing controls. Federal data validation requires a state process, and California’s WSD24-16 operationalizes that process through local records, annual validation, corrections, and technical assistance.
At a glance
Agency
USDOL / USDOE
Guidance
TEGL 07-18, Change 1
Issued
July 10, 2025
Status
Continuing
Joint validation
25 common data elements
State responsibility
Written procedures + monitoring + corrections
California implementation
WSD24-16 + source-document guidance
Executive takeaway
WIOA Section 116(d)(5) requires each state to develop procedures that ensure performance data are valid and reliable. TEGL 07-18, Change 1 gives DOL and Education a common framework across the six WIOA core programs so the same federal performance measures are supported by consistent data definitions and source-document standards.
The federal guidance leaves the design of the validation system to each state, but it does not leave the core controls optional. States must have written procedures, regular staff training, monitoring protocols, recurring review for missing or anomalous data, evidence that errors are corrected, and periodic evaluation of whether the validation process itself is working.
Five things to know
- Data validation is an internal-control and quality-assurance system, not just a federal audit activity.
- States must regularly validate 25 jointly required data elements through core-program monitoring.
- The federal attachment identifies acceptable source-document types for those common elements.
- States may validate more elements and require additional documentation beyond the joint federal list.
- For the jointly validated elements, self-attestation or participant self-reported supplemental wage information through follow-up may be used only after efforts to collect other allowable source documentation have been exhausted.
The federal validation control cycle
1. Define
Maintain written procedures explaining how data errors or missing information are identified and corrected.
2. Train
Provide recurring validation training to appropriate program staff. DOL gives annual training as an example of a regular schedule.
3. Review + monitor
Regularly review data for errors, missing values, out-of-range values, and anomalies and monitor whether staff follow the procedures.
4. Correct + improve
Document correction of erroneous or missing data, assess whether the process is effective, and revise the process when recurring problems remain.
Why the 25 common elements matter
DOL and Education selected 25 common data elements because they are especially important to accurate performance outcomes and cross-program consistency. They include participation and exit dates, education and training indicators, employment outcomes, and credential-related information. Attachment I pairs those elements with acceptable source documentation.
| Source-document type | What it means |
|---|---|
| Cross-match | Evidence from another detailed database, supported by appropriate data-sharing arrangements and sufficient detail to verify the reported element. |
| Self-attestation | A participant-generated, signed and dated written or electronic declaration that is traceable to the participant. |
| Case notes | A staff record that identifies the participant’s relevant situation/status, the date the information was obtained, and the staff person who obtained it. |
| Electronic records | Participant source documents or official service records maintained in the MIS or another official recordkeeping system. |
Hierarchy matters: if several sources conflict, the federal guidance says the most authoritative source should be used to decide whether the element is valid and accurate. Self-attestation is not a universal substitute for a more authoritative document where the joint guidance requires other allowable sources to be exhausted first.
How the federal framework reaches a California Local Board
Federal
TEGL 07-18, Change 1 defines the joint validation framework and source-document expectations.
California
EDD develops the statewide validation process and source-document procedures, including WSD24-16 and related documentation policy.
Local Area
Participant files, CalJOBS records, provider documentation, corrections, and staff practice create the data California validates and reports federally.
Validation should change the workflow, not just the sampled file
The federal framework explicitly connects data validation with performance accountability and internal controls. When a validation review finds a recurring problem, the meaningful corrective action is not simply fixing the sampled CalJOBS record. Local Areas should identify the intake, eligibility, case-management, provider, training, exit, or follow-up process that generated the bad data and correct that process.
WDB implementation considerations
- Align local source-document checklists with current EDD and federal definitions rather than maintaining a separate local interpretation.
- Train program, provider, and MIS staff on the same validation expectations and data definitions.
- Conduct periodic local checks before EDD’s formal sample arrives.
- Track recurring errors by data element, provider, staff workflow, and root cause.
- Correct both the record and the process that generated the error.
- Make sure self-attestation and self-reported wage information are used only where the applicable federal and California documentation rules permit them.
Implementation traps
- Waiting for the EDD validation cycle before checking source-document quality.
- Assuming a value entered in CalJOBS is automatically validated because staff know it to be true.
- Using self-attestation as a convenience when a more authoritative allowable source is required or reasonably available.
- Fixing individual sampled records without addressing the workflow that created the error.
Source basis and interpretation
Primary federal source: USDOL TEGL 07-18, Change 1 — Validating Jointly Required WIOA Performance Data
California implementation: EDD WSD24-16 — WIOA Data Validation and current California source-documentation guidance.
How to use this brief: Federal requirements summarize the joint data-validation framework. California may validate additional elements or require additional source documentation. For local case decisions, use current EDD validation and source-documentation rules.