JTPA Title III grants for worker profiling and reemployment services

Training and Employment Guidance Letter No. 3-94

Issue date: November 10, 1994
Classification: JTPA
Correspondence symbol: TWRA
Expiration date: Continuing

TO: All State JTPA Liaisons; State Employment Security Administrators; State Worker Adjustment Liaisons

FROM: Barbara Ann Farmer, Administrator for Regional Management

SUBJECT: JTPA Title III Financial Assistance for Implementing Worker Profiling and Reemployment Services Systems

Purpose. To provide information on the expected role of JTPA Title III program operators in implementing worker profiling and reemployment services systems within each State; and to announce the availability of supplemental JTPA Title III funds to assist States in [text ends in ETA's migrated field].

References. a. Unemployment Compensation Amendments of 1993 (Public Law 103-152); b. Training and Employment Guidance Letter (TEGL) 8-93, dated April 25, 1994; "Final Planning Guidance for Job Training Partnership Act Title III State Plans for Program Years (PYs) 1994/1995; c. "Implementation of a System of Profiling Unemployment Insurance (UI) Claimants and Providing Them with Reemployment Services;" Supplement No. 1, Supplement No. 2.

Background. Implementation of UI claimant profiling is an important component of the Department of Labor's (DOL) comprehensive workforce strategy. Claimant profiling and referral to reemployment services will become a primary way of ensuring early intervention assistance to dislocated workers. Referral of profiled UI claimants will be added to rapid response and other outreach and intake efforts for self-referral as the means by which dislocated workers will access reemployment assistance under JTPA Title III or Wagner-Peyser grants. The worker profiling and reemployment services concept encompasses two fundamental principles: 1. the early identification of UI claimants who are likely to exhaust their UI benefits before obtaining employment and, thus, who qualify as dislocated workers; and 2. the timely referral of claimants identified as likely to exhaust UI benefits to quality reemployment services. This service process is designed to shorten the time required to return to productive, stable employment. It also ensures that dislocated workers who may not have been identified through rapid response will be made aware of services available under both JTPA Title III and Wagner-Peyser, so that they can begin the readjustment process as early as possible.

Worker Profiling and JTPA Title III.

a. Overall Objectives and Principles. The successful implementation and operation of a worker profiling and reemployment services system requires effective joint planning and cooperative efforts among all agencies and organizations responsible for administering or operating the unemployment compensation, employment service, dislocated worker and labor market information programs within the State. To be effective, the components of the system -- identification, selection and referral, reemployment services, and feedback -- must be linked and must be developed at comparable levels of quality. A quality process for identification and selection does not accomplish the objective if there is not a quality set of reemployment services to which individuals can be referred. In short, the service process must operate as an integrated system of service delivery and not just a summation of service through two or more components. With an increase in funding from $500 million to $1.1 billion in Program Year 1994, the Department of Labor expects that the JTPA Title III program will be a major provider of reemployment services to UI claimants identified as likely to exhaust their UI benefits. Individuals identified through profiling will have the same characteristics and needs as dislocated workers currently being served through the Title III program. Consequently, the Department does not expect that service to individuals identified through profiling should have any negative effect on the ability of Title III service providers to meet current performance standards. At the same time, the Department recognizes that implementation of a worker profiling and reemployment services system represents a substantial impact on the JTPA Title III program, both in terms of the demand for services and the structure for providing services. The initiative creates an opportunity for using the increased funds in PY 1994 to not simply increase service levels through the existing service approach, but to restructure the service approach to achieve improvements in productivity and service quality. Governors are strongly encouraged to use funds under Section 302(c), which are not subject to the minimum expenditure for retraining requirement, to provide support to the worker profiling and reemployment services system in the State. Governors are also encouraged to work with the substate grantees to explore the issues of waiving the minimum expenditure requirement for retraining as provided for at Section 315(a)(2) of the Act so that additional amounts of Title III funds can be directed to basic readjustment services. Finally, Governors are encouraged to establish, through the State agencies responsible for implementing this initiative, seamless service delivery procedures so that eligibility determinations are completed, to the maximum extent possible, on individuals before they are referred to specific service providers for reemployment services.

b. Specific Implications. Profiling becomes another source of referrals of dislocated workers into the Title III service system. The State and substate grantees continue to be responsible for ensuring that services are provided to eligible individuals and in accordance with the provisions of JTPA and the September 2, 1994, Regulations. Because the Unemployment Compensation Amendments create a mandatory participation requirement for individuals identified through profiling and referred to reemployment service providers, the State, as suggested in the previous section, should take steps to ensure that the eligibility of individuals to receive Title III funded services is established prior to referral to Title III service providers. Current policy regarding the point at which eligible individuals must be enrolled as participants in the Title III program will continue to apply. Title III funds may be used to pay the cost of outreach, eligibility determination, and an assessment of suitability for available assistance prior to enrollment, but receipt of services beyond these requires that the individual be enrolled as a participant in the Title III program. In the context of the profiling and reemployment services system, pre-enrollment activities can include orientation, a determination of eligibility for Title III services, and review of information to confirm that the individual has been appropriately referred to the Title III program. The implementation guidance on the Worker Profiling and Reemployment Services System states that referral of individuals identified through profiling will occur in accordance with agreements between UI and reemployment service providers on the capacity to accept and provide assistance to such individuals. The Department expects that State and substate Title III program operators will not use this provision as a basis for screening out or limiting the service capacity available for dislocated workers identified and referred through profiling. Rather, this provision will be used to ensure that individuals are not referred to providers who do not have the current capacity to provide services to them. Since UI claimant profiling will become an increasingly significant source of dislocated worker outreach and referral, the Department expects that Title III program operators will be taking steps to improve their capacity to provide quality services to larger numbers of dislocated workers and that a significant portion of that capacity will be available to eligible individuals identified and referred through profiling.

Availability of Supplemental Funds. The Department is making available in PY 1994 up to $20 million, from Title III funds reserved for the Secretary, in supplemental financial assistance to States to ensure effective implementation of a worker profiling and reemployment services system. These limited resources are available on a one-time basis only and should not be viewed as an ongoing source of financial assistance. Supplemental funds are available for start-up and quality/productivity improvement costs only. They may not be used to increase service levels to a point which will not be sustainable in the absence of the supplemental assistance. Some of the prototype States have received supplemental funds for early implementation. First and Second Wave States that can demonstrate a need for additional, one-time funds, and have a well developed strategy for improving productivity and service quality for dislocated workers are invited to apply for supplemental Title III funds. Funds will be provided to the designated State agency which administers the JTPA Title III program. Within the State, funds can be provided to and used by any organizational entity which is involved in providing reemployment services to eligible dislocated workers through the State's Worker Profiling and Reemployment Services system.

Procedures and Criteria for Award of Supplemental Funds.

a. Allowable Uses of Funds. The funds which are available to the States are JTPA Title III funds and must be used in a manner consistent with the provisions of Title III of the Act. That is, funds can only be used for activities and cost items authorized under Title III for eligible dislocated workers.

b. Priorities for Use of Funds. Funding requests will be evaluated according to the following criteria:

• First and foremost, the State has made or will make a substantial contribution of State formula (both Title III and Wagner-Peyser) funds to support the reemployment services component for the worker profiling and reemployment services system.

• There is a clear demonstration that the requested funds are not to cover ongoing operational costs related to increased service levels and/or that there will be a fund source to pick up any continuing future operational costs.

• Highest priority will be given to costs designed to improve the long-term quality and productivity of the reemployment service system; and to effectively implement new integrated operational relationships. Such costs could include staff training in improved service methods, implementing technologies and methods by which participants can self-access services and information, and integrated information systems (including the feedback mechanism required in the worker profiling and reemployment services system).

• Lowest priority will be given to funding the costs of direct service staff positions. Proposals which request funds to simply serve more individuals at current, or higher, cost per participant levels will not be considered. In general, requests should not exceed ten percent of the State's PY 1994 JTPA Title III allotment. An appropriate percentage will vary according to the size of the State's allotment (i.e., the percent should be smaller for States with large allotments and PY 1994 increases, and vice-versa). The guidelines described in this issuance will be used to review all requests for supplemental JTPA Title III funds from First and Second Wave States. For Prototype and First Wave States which have already received approved supplemental funding, requests for additional supplemental funding will be not be considered, but such States may submit modifications regarding the use of supplemental funds in accordance the priorities described in this issuance.

c. Submission of Supplemental Requests. Requests for supplemental funds should be submitted to:

The Office of Worker Retraining and Adjustment Programs
U.S. Department of Labor
Room N-5426
200 Constitution Ave., NW
Washington, DC 20210
ATTN: Maurice Birch

The request shall be submitted by an authorized signatory of the designated State agency which administers the JTPA Title III program. A copy of the request should simultaneously be submitted to the appropriate Regional Office. The format for the submission is included as an attachment.

d. Award of Funds. All requests from designated First Wave States should be received no later than December 1, 1994. Approved funds will be awarded within 60 days, or by February 1, 1995, as part of or through a modification to the partnership agreement. All requests from Second Wave States should be received no later than June 1, 1995. Approved funds will be awarded within 60 days, or by August 1, 1995, as part of or through a modification to the partnership agreement.

Action. States which have developed plans for implementing a worker profiling and reemployment services system, and which require supplemental funds to effectively implement the reemployment services component of the system, should prepare and submit a request for such funds in accordance with the guidelines and procedures described in this issuance. For those States which have already submitted a request for supplemental Title III funds, these requests will be evaluated as submitted unless the State chooses to submit additional or modified information by the indicated deadlines.

Attachment: Format and Requirements for Request for Supplemental JTPA Title III Funds to Implement Worker Profiling and Reemployment Services System

(1) Completed and signed Standard Form 424 and Financial Forms.

(2) A line-item budget describing proposed costs to be covered by requested funds, and delineating costs between administration and basic reemployment services cost categories.

(3) The following information:

• the number of individuals estimated to be identified as "likely to exhaust UI benefits" through the profiling procedure during the first year of system operation;

• the number of individuals identified above who will be referred to reemployment services;

• an estimate of the average per unit cost of providing reemployment services to individuals identified through profiling as "likely to exhaust UI benefits", and the per unit cost of providing basic readjustment services to dislocated workers in the Title III program during PY 93;

• the amount of funds, identified by source, from the State's Wagner-Peyser Grant, the substate allocation of JTPA Title III funds, the funds reserved by the Governor from the State's Title III allotment, and any other State funding source, which are being committed to provide reemployment services to individuals identified through profiling.

(4) Where supplemental funds are being requested for the cost of capacity building efforts to establish a long-term capability to provide quality reemployment services, an identification of the specific activities and description of how the activities are expected to increase the quality of reemployment services and/or the productivity of service staff (i.e., the ability of each staff to serve more individuals). [Capacity building activities can include staff training, investments in self-access, self-directed service technologies, development and implementation of feedback systems, and other actions designed to increase program capacity, service quality and staff productivity.]

(5) Where supplemental funds are being requested for additional staff to serve more individuals, or for procured services from service providers to serve more eligible individuals, a description of how service levels in the first year will be maintained in subsequent years without supplemental federal funding.