July 2, 2026 – CHILDREN AT RISK appreciates the Sunset Advisory Commission staff review of the Texas Workforce Commission (TWC). The staff report describes ways to strengthen the administration, accountability, transparency, technology infrastructure, and coordination of workforce and child care programs that affect children, families, young adults, and vulnerable populations.

The linked comments below consolidate CHILDREN AT RISK recommendations related to child care program integrity and early childhood education, SNAP Employment and Training (SNAP E&T), Opportunity Youth and Young Adults (OYYA), and workforce supports for human trafficking survivors. We respectfully urge the Commission to adopt the Sunset staff recommendations and strengthen them with the targeted policy additions outlined below.

The Sunset Staff Report confirms several system-wide challenges that CHILDREN AT RISK has heard from families, service providers, and community partners. These challenges include fragmented systems, uneven implementation across Local Workforce Development Boards (LWDBs), flawed technology, insufficient transparency, inconsistent training, and limited cross-agency coordination. The challenges affect whether families can access child care, whether SNAP recipients can obtain meaningful training, whether young adults can reconnect to school or work, and whether human trafficking survivors can achieve long-term economic stability.

CHILDREN AT RISK recommends that the Sunset Commission strengthen the TWC review in four priority areas:

PRIORITY AREAS:

• Strengthen the integrity of the child care program, increase access to early childhood education, and better coordinate the system. This can be done by retaining and strengthening Sunset Recommendations 4.1-4.7, 5.4-5.6, 6.1-6.3, and relevant Issue 1 LWDB oversight and training recommendations. TWC should develop TX3C/KinderConnect corrective action, contractor audits, public board-level CCS data, cross-agency early childhood coordination, and improved Market Rate Survey with cost-of-care analysis.

• Transform SNAP E&T from a compliance program into a workforce strategy by strengthening Sunset Recommendation 1.8, 1.9 and related IT modernization recommendations 4.1-4.4 to recognize and align SNAP E&T participation to education and credential pathways to economic mobility, standardize Third-Party Partnership administration, improve quality and guidance, modernize TWC-HHSC data sharing, maximize federal funds, and publicly report outcomes.

• Create a statewide strategy for Opportunity Youth and Young Adults (OYYA) that builds on Sunset Commission recommendations regarding coordination, TWC’s oversight of OYYA-serving programs, technology modernization, and performance measurement — leading to the adoption of a statewide definition, a shared data framework, youth-focused metrics, a cross-agency advisory structure, and enhanced navigation supports.

• Embed trauma-informed workforce supports for human trafficking survivors by building on Sunset recommendations related to standardized training, coordination, accountability of LWDB, and modernization of technology to establish dedicated navigators, survivor-centered training, consistent service standards, formal partnerships, and outcome tracking.

Related: Click here to read all of CHILDREN AT RISK’s recommendations for the Texas Sunset Advisory Commission.