There Are No Hard-to-Serve Learners, Only Ill-Served Ones - Erik Jacobson

Oct 15, 2026

The paper examines the Workforce Investment and Opportunity Act (WIOA) evaluation framework and questions the assumption that “hard-to-serve” learners are inherently difficult. It argues that barriers such as low English literacy, disabilities, unstable housing, economic vulnerability, and prior criminal justice involvement do not automatically explain why individuals would be harder to serve. By analyzing policy language and interpreting the term in multiple ways—disposition-level, skill-level, and program-enrollment choices—it highlights how the label can be tautological and pejorative while obscuring systemic factors.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages5

Reading Time13 min

AccessFree to download

Forum: Serving Learners with Barriers

Part 1 of 3

The meaning of “hard-to-serve” within WIOA

Why barriers may not explain difficulty

Interpretations: disposition, skills, and systemic issues

ADULT LITERACY EDUCATION Winter 2021 [http://doi.org/10.35847/EJacobson.3.1.55](http://doi.org/10.35847/EJacobson.3.1.55) Forum: Serving Learners with Barriers (Part 1 of 3) There Are No Hard-to-Serve Learners, Only Ill-Served Ones Erik Jacobson, Montclair State University Since it was signed into law, the Workforce Investment and Opportunity Act (WIOA) has been the subject of continuing scrutiny. One commonly shared concern is that the evaluation metrics ofthe Act (e.g., employment, salary, etc.) may incentivize programs to work with learners who will more readily meet expected outcomes (Pickard, 2016). Others suggest this concern is misplaced, pointing to the fact that the Act explicitly notes that the models created for State and program evaluation will be adjusted to recognize the priority given to serving students who face significant barriers (Wilson, 2015). These barriers include low levels of English and/or literacy, disabilities, limited work experience, lack of stable shelter, economic vulnerability and being an ex-offender. Learners who face these barriers are often identified as being part of hard-to-serve populations, both in policy documents and in commentary in the field. However, it is unclear what the term actually means. These populations may face difficult barriers, but why do those barriers make them harder to serve than other students? Why are certain populations singled out in this way? What purpose does it serve to attach a pejorative label to them? Within the language ofWIOA, it often seems like the definition of hard to serve is tautological in nature – that is, it is defined by the hard-to-serve populations it describes. In the WIOA Final Rule, it explains how the evaluation process is intended to account for the nature of the student population served in this way: the model will increase the performance levels required ifa State or local area were to serve lower-than-anticipated percentages of hard-to-serve populations with barriers to employment because it would presumably be easier to serve these individuals. Similarly, performance levels (or targets) would be decreased if a State or local area were to serve a higher-than-anticipated percentage of individuals with barriers, because these individuals are harder to serve. (U.S. Department of Labor and Department of Education, 2016, p. 55866) In other words, it is more difficult to serve students with barriers that make them hard to serve. This truism does not provide any more clarity on what about those barriers make hard-toserve learners so different from other learners. In addition to those noted above, the Act presentsa number of other potential barriers that can lead to somebody being described as hard to serve, including receiving TANF or other assistance (p. 55841), taking a longer time to achieve a positive outcome (p. 55842), or being foreign born (p. 55866). Again, in none of these cases is it explained why individuals in these populations are harder to serve – it is seemingly taken for granted. The phrasing itself suggests that it is infact an issue with the learner – something about Correspondence: [jacobsone@montclair.edu](jacobsone@montclair.edu) 55 them is seen as creating difficulties. However, what about a learner being foreign-born is problematic for a program providing education or training? Why would these students be harder to serve than learners born in the United States? The answer cannot be their need to improve their English skills, since that is the very purpose of English as a second language programs. Because the term is not explained or elaborated on, hard to serve is open for interpretation. For example, one reading of the concept of hard-to-serve learners suggests that there is an issue with the learner’s disposition. Consider the connotation of phrases like hard to please or hard to talk to. If a potential learner does not accept an offer to enroll in a particular program, they maybe writ

FAQs

What does the paper say about the term “hard-to-serve learners” under WIOA?

It argues that the definition is often tautological—learners are labeled hard to serve mainly because they are described as belonging to hard-to-serve populations. The policy language does not fully explain why these barriers make serving more difficult.

Which barriers are listed as examples of “hard-to-serve” populations?

Examples include low English and/or literacy, disabilities, limited work experience, lack of stable shelter, economic vulnerability, being an ex-offender, receiving TANF or other assistance, taking longer to reach outcomes, and being foreign born.

Why does the author criticize treating “hard to serve” as an issue with the learner alone?

The author contends that alternative readings of the term—such as disposition problems or skill gaps—still risk using a deficit model or blaming individual affect. Participation and persistence are framed as systemic issues shaped by programs and broader systems, not solely personal responsibility.

Oct 15, 2026

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