Under the Workforce Innovation and Opportunity Act, a person is “basic skills deficient” if they are a youth whose English reading, writing, or computing skills test at or below the eighth-grade level on a generally accepted standardized test, or a youth or adult who cannot compute, solve problems, read, write, or speak English at a level needed to function on the job, in the family, or in society. The label matters because it opens the door to WIOA youth services and gives adults mandatory priority for career and training services.
Where the Definition Comes From
The term is defined at Section 3(5) of WIOA, codified at 29 U.S.C. § 3102(5).1Cornell Law Institute. 29 U.S.C. § 3102 – Definitions The statute uses two prongs. One is a grade-level test: youth with reading, writing, or math skills “at or below the 8th grade level on a generally accepted standardized test.” The other is a functional test: an individual who “is unable to compute or solve problems, or read, write, or speak English, at a level necessary to function on the job, in the individual’s family, or in society.”
Federal regulations at 20 C.F.R. § 681.290 restate the criteria and require state and local workforce development boards to set their own policies for applying the functional prong. Assessments must be valid and appropriate for the target population, and reasonable accommodations must be provided for people with disabilities.2GovInfo. 20 CFR § 681.290
Who Each Prong Applies To
The eighth-grade standardized-test threshold applies only to youth. There is no fixed grade-level cutoff in the statute for adults or dislocated workers. Both groups are evaluated under the functional standard: whether they can read, write, compute, solve problems, or speak English well enough to manage daily responsibilities.3Partner4Work. WIOA Adult and DW Eligibility Policy Many local areas still give adults the same standardized tests and use grade-level scores as evidence of functional deficiency, but the legal standard for adults is functional, not a rigid score.
How the Determination Is Made
States and local workforce boards choose from a range of approved assessment tools. Two dominate: the Test of Adult Basic Education (TABE) and the Comprehensive Adult Student Assessment Systems (CASAS).
TABE
TABE scale scores map to Educational Functioning Levels set by the National Reporting System. For WIOA youth, a score at NRS Level 4 or below, which corresponds to roughly the eighth-grade level, qualifies as basic skills deficient. Kentucky, for example, uses TABE cut scores of 549 or below in reading, 556 or below in math, and 559 or below in language.4Kentucky Workforce Innovation Board. Using TABE to Determine Basic Skills Deficiency Other states use a grade-level equivalent of 8.9 or below on any NRS-approved exam.5WorkSource Southwest Washington. Determining Basic Skills Deficiency Currently approved versions are TABE 11/12 and TABE 13/14.
CASAS
Where CASAS is used, NRS benchmarks map reading scores of 238 or below and math scores of 235 or below to Level 4 or below, roughly a seventh- or eighth-grade level.6Washington Workforce Training Board. WorkSource System Policy 1011, Revision 6 The published crosswalk places CASAS reading scores of 228 to 238 at ABE Level 4, equivalent to grades seven through eight.7Washington Workforce Coordinating Board. CASAS EFL Chart
Other Accepted Evidence
Local boards can accept other instruments and records. New York’s GLOW Workforce Development Board accepts the Wide Range Achievement Test, the ASVAB, the National Work Readiness Credential assessment, school records such as report cards or Individualized Education Programs, and a state skills assessment form.8GLOW Workforce Development Board. Basic Skills Deficient Policy South Dakota uses ACT WorkKeys, treating a Level 4 or below result as basic skills deficient. A Gold-level National Career Readiness Certificate or higher exempts an individual from the determination; a Silver or Bronze certificate means the individual meets the deficiency criteria.9South Dakota Department of Labor and Regulation. Basic Skills Deficient Policy
Screening at Adult Intake
Because the adult standard is functional, some states use a short intake questionnaire instead of a full standardized test. Arizona’s screening tool asks four questions about following written instructions, completing forms, doing basic arithmetic, and using a computer. Answering “no” to any question, or being unable to complete the form independently, results in a basic-skills-deficient determination for Adult and Dislocated Worker services.10Arizona@Work. Basic Skills Screening Tool Other areas do the same, saving full testing for people entering training-level services or needing documented skill gains for performance reporting.11Ohio Workforce Board. Basic Skills Assessment Procedure – Adult/DW
Documentation Rules You Need to Know
Basic skills deficient is unusual among WIOA eligibility elements: self-attestation is not acceptable documentation. Federal guidance in TEGL 09-22 identifies it as the only youth eligibility element where a signed participant declaration does not suffice.12U.S. Department of Labor. TEGL 09-22 School status, date of birth, disability, homelessness, and foster-youth status can all be self-attested. This one requires an actual assessment or record.
Assessment results generally must be no older than six months. Programs may accept older results if the state or local area has a policy allowing it and circumstances make retesting impractical, with the caution that assessments should not deter enrollment.12U.S. Department of Labor. TEGL 09-22
Why the Designation Matters
Youth Eligibility
For out-of-school youth who already hold a high school diploma or equivalent, being basic skills deficient is one of the specific barriers that can qualify them for WIOA youth services. OSY using this barrier must also be documented as low-income.12U.S. Department of Labor. TEGL 09-22 For in-school youth, basic skills deficiency combined with low-income status makes the individual eligible.13South Carolina Department of Employment and Workforce. State Instruction 19-05, Change 3
A five-percent exception lets a limited share of youth enroll without documenting low-income status. OSY who hold a diploma and are basic skills deficient are among the categories that can be counted under it.14New York State Department of Labor. Youth Eligibility
Adult Priority of Service
Under the WIOA Adult program, basic skills deficient is one of three categories that receive mandatory priority for individualized career and training services, along with recipients of public assistance and other low-income individuals. The priority applies regardless of how much funding a local area has.15U.S. Department of Labor. WIOA Adult Program[/mf] Veterans receive their own layer of priority across DOL-funded programs, and federal guidance has not settled how to rank veterans against the three statutory priority groups when they overlap.16Center for Law and Social Policy. Priority of Service Brief
How It Differs From English Language Learner Status
WIOA treats “basic skills deficient” and “English language learner” as separate legal categories, listing them as independent criteria for program eligibility.17New Hampshire Department of Education. WIOA Glossary They overlap because the functional prong of the BSD definition includes being unable to read, write, or speak English well enough for daily life. An English language learner with documented limited English proficiency may qualify as BSD on that basis, but the two statuses are not automatically equivalent. Some local areas accept a self-attestation that a person’s primary language is not English and their English is limited; others require a standardized test score.18RochesterWorks. Basic Skills Deficient Policy
What Happens After the Determination
Once enrolled, participants identified as basic skills deficient are tracked for measurable skill gains, an in-process performance indicator that captures educational or training progress during the program year. A gain can be shown by:
- An educational functioning level gain documented through NRS-approved pre-tests and post-tests showing at least one level of improvement.
- Earning a secondary school diploma or its equivalent.
- A transcript or report card showing satisfactory academic progress in secondary or postsecondary education.
- Training milestones reported by an employer or training provider, such as completion of on-the-job training phases or pay increases.
- Passing an occupation-specific exam or knowledge benchmark required for a credential.
Only the most recent gain per participant per program year counts toward the performance measure, though all gains are documented.19California Employment Development Department. WSD 24-0720Wisconsin Department of Workforce Development. WIOA Policy 11.17 – Measurable Skill Gains
A Change on the Horizon
WIOA’s original authorization has expired, and Congress has been working on reauthorization. In April 2026, the House Education and Workforce Committee passed H.R. 8210, “A Stronger Workforce for America Act of 2026,” on a 19-14 party-line vote. The bill would replace “basic skills deficient” with “foundational skill needs” and expand the definition to cover individuals who lack digital literacy skills at a level needed to function in education, employment, family life, or society.21Afterschool Alliance. House Education and Workforce Committee Advances Workforce Bill It would also add AI literacy as an allowable use of workforce funds.22National Skills Coalition. WIOA Reauthorization Is Back, but Partisan Changes Complicate Its Path Forward The bill lacks bipartisan support, so its path in the Senate is uncertain.