The Center for Law and Social Policy (CLASP) is very pleased that Congress, in passing the Workforce Innovation and Opportunity Act (WIOA), included an interim measure of progress as one of the six "primary indicators of performance." This common measure offers an opportunity to ensure WIOA funds are used to provide services for participants with initially low basic skills, including English language learners. Recognizing that these individuals will require additional services and a longer timeframe to succeed in postsecondary education and the labor market, this measure helps programs demonstrate success through interim outcomes achieved by this population. The "skill gains" measure can also promote unified planning and shared accountability, as well as support longer-term and more integrated interventions, such as career pathway approaches, which are encouraged in WIOA. In developing regulations and guidance for implementing the skill gains performance indicator, CLASP invites the U.S. Departments of Education and Labor to consider the recommendations offered herein.