The Workforce Innovation and Opportunity Act (WIOA) modernizes the federal framework that guides America's public workforce system and increases the system's accountability in supporting the employment needs and interests of adults and youth facing barriers to employment. We strongly support this vision of WIOA and look forward to working with the Departments of Labor, Education as well as other federal agencies responsible for administration of partner programs to support the successful implementation of the law. The NPRMs released by the Departments in April 2015 are a critical step towards achieving this vision. Our comments reflect input from our coalition members in nearly every state in the nation and a range of stakeholders including workforce and human services practitioners, anti-poverty organizations, researchers, and others. Throughout our comments we note areas where we believe the draft rules are consistent with the intent of the law, as well as areas where we believe additional regulatory clarification or guidance may be needed and/or where we believe further consideration is warranted by federal agencies as WIOA is implemented to ensure that adults and youth facing barriers to employment are served well.