SCSEP state plan modification instructions

                                                        CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION               SCSEP
               ADVISORY SYSTEM                          CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                      DNPTTA
             Washington, D.C. 20210                     DATE
                                                         October 1, 2014

ADVISORY:       TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 8-14

TO:             Senior Community Service Employment Program Grantees
                State Governors
                State Workforce Administrators
                State Workforce Liaisons
                State and Local Workforce Board Executive Directors and Chairs

FROM:           PORTIA WU /s/
                Assistant Secretary

SUBJECT:        Senior Community Service Employment Program State Plan Modifications

1. Purpose. The purpose of this Training and Employment Guidance Letter (TEGL) is to
   provide guidance to Senior Community Service Employment Program (SCSEP) grantees for
   modifying unified, integrated, and stand-alone State Plans that were approved in 2012.

2. References.
       Older Americans Act, as amended in 2006, Public Law 106-501 Section 503(a)(1)
       SCSEP Final Rule, 20 CFR 641.302-365 (September 10, 2010)
       State Integrated Workforce Plan Requirements for Workforce Investment Act Title
         I/Wagner-Peyser Act and Department of Labor Workforce Programs (OMB Circular
         No. 1205-0398)
       Planning Guidance for State Unified Plans and Unified Plan Modifications Submitted
         under Section 501 of the Workforce Investment Act (OMB No. 1205-0398)
       TEGL 21-11, Requirements for 2012 State Workforce Plans, March 27, 2012
       TEGL 03-14, Implementing a Job-Driven Workforce System

3. Background. In 2012, the Department of Labor, Employment and Training Administration
   (ETA) updated the requirements governing state planning for all agency-funded programs.
   ETA issued two sets of guidance, allowing states to submit integrated or unified plans. The
   State Integrated Workforce Plan Requirements for Workforce Investment Act Title I/Wagner-
   Peyser Act and Department of Labor Workforce Programs guidance was for states that
   submit Integrated Workforce Plans; and Planning Guidance for State Unified Plans and
   Unified Plan Modifications Submitted under Section 501 of the Workforce Investment Act
   (WIA) was for states that submitted a Unified Plan. SCSEP grantees had the option of
   submitting the SCSEP portion within either plan, as a separate standalone SCSEP plan or
   both.

 RESCISSIONS                                            EXPIRATION DATE
 None                                                   Continuing

    SCSEP regulations require that either the Governor or the highest state governmental
    official review and submit an update to the State Plan every 2 years (20 CFR 641.340(a)).

    SCSEP grantees must make the modified plan available for public comment before
    submission (20 CFR 641.345(c)). The regulations allow but do not require the state to seek
    the advice and recommendations of involved individuals and organizations affected by
    changes to the plan (20 CFR 641.345(d)).

    This TEGL describes modification requirements and submission instructions for the 2014
    SCSEP State Plans as required under the Older Americans Act. The Workforce Innovations
    and Opportunities Act (WIOA) provisions are effective as of July 1, 2015, and do not
    impact the SCSEP State Plan modifications for 2014. ETA will issue regulations and
    guidance on the new Unified State Plans and Combined State Plans under WIOA in 2016.

    The SCSEP state plans offer several opportunities to review how SCSEP grants align with
    and advance an integrated, effective, job-driven workforce system, as described in TEGL
    No. 3-14. SCSEP grant plans ask states to consider several of the features of a job-driven
    workforce system, including: strong partnerships to support the comprehensive service
    needs of SCSEP participants; enhanced business engagement to increase use of appropriate
    on-the-job experience and to increase placement into unsubsidized employment; and using
    SPARQ and other program data to inform strategic decisions on services offered and
    industries targeted, and for continuous improvement. Together, incorporating these
    elements into program planning and operations prepares SCSEP participants for self-
    sustaining employment and economic stability after program exit.

4. Required Updates to SCSEP State Plans. SCSEP State Plans cover planned activities for
   the next 4 years, and are updated every 2 years. This year, all states must modify their
   SCSEP State Plan to describe activities and services for 2014-2018. For State Plan
   Modification requirements, please see Attachment I. Modifications must address all of the
   following that are applicable:

          Changes in long-term industry or occupational outlook that affect employment
           opportunities for older workers (20 CFR 641.302(d)).

          Changes in long-term employment projections that affect the types of unsubsidized
           jobs available for SCSEP participants, and the types of skill training they receive (20
           CFR 641.302(d).

          Changes in current or projected employment opportunities in the state, and the types
           of skills possessed by eligible individuals (20 CFR 641.325(c)).

          Changes in the localities served, or changes in the characteristics of the populations
           served by SCSEP (20 CFR 641.325 (d)).

          Changes in how SCSEP coordinates with other programs including the following:

           1) Planned actions to coordinate activities of SCSEP grantees with WIA Title I
              programs, including plans for using the WIA One-Stop delivery system and its
              partners to serve individuals aged 55 and older. (20 CFR 641.302(g), 641.325(e))
           2) Planned actions to coordinate SCSEP grantee activities with the state activities
              being carried out under the other titles of the Older Americans Act (20 CFR
              641.302(h)).
           3) Planned actions to coordinate SCSEP with other private and public entities and
              programs that serve older Americans, such as community and faith-based
              organizations, transportation programs, and programs for those with special needs
              or disabilities (20 CFR 641.302(i)).
           4) Planned actions to coordinate SCSEP with other labor market and job training
              initiatives (20 CFR 641.302(j)).
           5) Actions to ensure that SCSEP is an active partner in the One-Stop delivery system
              and the steps the state will take to encourage and improve coordination with the
              One-Stop delivery system (20 CFR 641.335).

          Changes in the state’s long-term strategy for engaging employers to develop and
           promote opportunities to place SCSEP participants in unsubsidized employment (20
           CFR 641.302(e)).

          Changes in any of the requirements listed in 20 CFR 641.345(b), such as changes in
           Federal law or policy that affect the state plan’s functions; changes in performance
           indicators, or organizational responsibilities; changes in grantee or grantee functions;
           or when the state has failed to meet performance goals and must submit a corrective
           action plan.

5. Public Comment and Submitting Modifications to the SCSEP Portions of State Plans.
   Whether a state previously submitted the SCSEP plan as a standalone plan, as part of the
   Integrated Workforce Plan, or as part of a Unified Plan, states have options for updating their
   2014 SCSEP State Plan. States can describe their updates in a separate document, or can
   alter the original document. The state grantee should follow established state procedures to
   solicit and collect public comments on the modified State Plan.

   States should submit their State Plan modifications with “State Plan Modification” in the
   subject line to [email protected] on or before November 28, 2014. The Governor or
   the Governor’s designee submits the SCSEP State Plan. If the designee is submitting the
   plan, please attach a letter from the Governor naming his or her designee if you have not
   already provided ETA with a copy. Please send a copy to the appropriate Federal Project
   Officer (FPO) at the same time.

6. Inquiries. Please direct questions to the appropriate regional Federal Project Officer, please
   see Attachment II for FPO list and contact information.

7. Attachments.
   Attachment I: State Plan Modification Requirements
   Attachment II: FPO List and Contact Information

Attachment I: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2014/TEGL-8-14_Attachment-I_Acc.pdf

                           ATTACHMENT I
            SCSEP STATE PLAN MODIFICATION REQUIREMENTS

Following are the requirements for Senior Community Service Employment Program
(SCSEP) State Plan modifications. Grantees should only submit information on the
following subjects if there have been changes or if there are scheduled changes in the
next two years. If the state has any modifications or changes to any of the sections
described below, please make the changes and include them as part of the modified plan.

Section 1. Purpose of the State Plan Modification. The State Plan modifications allow
states to provide updated information on the longer term, strategic view of the SCSEP,
projected state changes in demographics, economy and the labor market. Modifications
of the State Plan should address the role of SCSEP with other workforce programs,
whether or not they serve older workers. Plan modifications should articulate how all
grantees will enhance the goals of the program. National grantees [except for those
exempt under Final Rule Section 641.320(b)] must coordinate activities and participate in
state planning activities in order to be eligible to receive SCSEP funds, thus state grantees
must seek the advice and recommendations of those national grantees operating in their
state as provided in 641.345(d).

Section 2. Involving Organizations and Individuals. Section 503(a)(2) of the Older
Americans Act (OAA) Amendments of 2006 requires that the State Plans describe the
state’s process for ensuring the involvement, advice and recommendations of
representatives from the following entities:

   • State Units on Aging and Area Agencies on Aging
   • State and Local Boards under the Workforce Investment Act (WIA)
   • Public and private nonprofit agencies and organizations providing employment
     services, including each grantee operating a SCSEP project within the state, except
     national grantees serving older American Indians or Pacific Island Asian
     Americans (although they are encouraged to participate) - see OAA Section
     503(a)(8)
   • Social service organizations providing services to older individuals
   • Grantees under Title III of the OAA
   • Affected communities (i.e., grantee service areas)
   • Unemployed older individuals
   • Community-based organizations serving older individuals
   • Business organizations
   • Labor organizations

States may also seek the advice and recommendations of other interested organizations
and individuals, including SCSEP participants, but this is not required by the statute.

In order to document statutorily required involvement of specific organizations and
individuals, grantees must include an appendix containing letters from all required parties
attesting to their participation in the state plan modification process.

Section 3. Soliciting and Collecting Public Comments. The State Plan must describe
how it ensures an open and inclusive planning process with meaningful opportunity for
public comment. Grantees must also include the state’s procedures and schedule and
comply with those procedures. Any individual or organization may comment on the
State Plan. (20 CFR 641.350)

Section 4. Increased Unsubsidized Employment and Employer Outreach. In this
section, the state must describe if there were changes in the overall goals and strategies
related to placing participants in unsubsidized employment, including 1) partnerships
with employers; 2) identifying employment opportunities with career potential; 3) placing
individuals in high-growth industries and occupations as well as industries and
occupations that provide substantial employment opportunities for participants; and 4)
retention activities to assist former participants to retain unsubsidized employment.

The modification must also discuss whether this strategy has increased grantee
performance levels for unsubsidized employment, including the grantee plans to improve
training during community service employment assignments. Such training may include
lectures or seminars, classroom or individual instruction, online instruction, private sector
on-the-job experience, work experience or other arrangements as described in OAA
Section 502(c)(6)(A)(ii).

The state plan modification must also specify what the state has done to ensure that the
state grantee is meeting its negotiated goal.

Section 5. Community Service Needs. The State Plan must identify the localities and
populations for which community service projects of the type authorized by SCSEP are
most needed. Once grantees identify unmet community service needs, they must specify
how they will recruit appropriate host agencies, including a prospective timeline.

The current and projected employment opportunities in the state and the types of skills
available among the eligible populations have direct implications for the host agencies
that grantees recruit to participate in the program; the types of training positions available
at the host agencies; skill training offerings that grantees locate or develop; and training
linkages that grantees negotiate and establish with the One-Stop. Grantees must discuss
how, if at all, the grantees in the state have collaboratively addressed those issues to
ensure that community service employment assignments are truly providing skill training
that meets the needs of both participants and employers and if they were successful.

Section 6. Coordinating with Other Programs, Initiatives, and Entities. The State
Plan must describe overall goals and strategies for coordinating SCSEP activities with
other entities, including the following:

   •   Coordination of activities with the state’s Title I WIA activities. The State Plan
       must described the steps the state is taking to ensure that SCSEP is an active

        partner in each One-Stop delivery system, and the actions it will take to encourage
        and further improve coordination with the One-Stop delivery system.
   •   State activities being carried out in the state under other titles of the OAA.
   •   Collaboration with other public and private entities and programs that provide
       services to older Americans, such as community-based organizations,
       transportation programs, and programs for those with special needs or disabilities.
   •   Collaboration with other partners, including state vocational rehabilitation
       agencies, adult education and literacy providers, and education and training
       providers such as community colleges.
   •   Collaboration with other labor market and job training initiatives.
   •   Leveraging resources from key state partners to support SCSEP activities,
       including state and local government agencies, foundations, employers,
       community-based organizations, and other entities.

Section 7. Avoiding Service Disruptions. The state must describe how their planned
actions will comply with the statutory requirement to avoid disruptions to participants. If
population, economic, labor market and/or skill sets indicate that there may have been
changes in eligible population or that there is over-enrollment for any other reason, the
Department recommends a gradual shift that encourages current participants in
subsidized community service assignments to move into unsubsidized employment to
make positions available for eligible individuals in the areas facing a relatively greater
need. OAA Section 518(a)(3)(B)(i) places time limits on SCSEP community service
assignments, requiring transition to unsubsidized employment.

Section 8. Improving SCSEP Services. The plan must describe any changes in the
long-term strategy to improve SCSEP services, including design changes to the program
and planned changes in the use of SCSEP grantees and program operators including
frequent formal collaboration activities among all SCSEP grantees within the state, more
stringent criteria to select sub-recipients, and sharing best practices.

Grantees may also make recommendations to the Department, on such topics as
allowable types of community services, deadlines for changes in the distribution of
positions, and strategies to improve services to minorities, veterans, and those most-in-
need.

Section 9. Distribution of SCSEP Positions within the State.

   A. Distribution of Positions. SCSEP 20 CFR 641.360 requires state grantees to
      prepare an equitable distribution report that describes how the state distributes
      positions (or “slots”). SCSEP 20 CFR 641.325 requires state grantees to include a
      written summary describing the ratio of eligible individuals in each service area to
      the total state eligible population in their State Plan. When preparing their State
      Plan, we recommend that States leverage their most recent Equitable Distribution
      (ED) report when describing the current distribution of individuals being served
      along with a summary of the areas, if any, significantly under-served or over-
      served.

   B. Rural and Urban Population Distribution. Information about the relative
      distribution of eligible individuals residing in rural and urban areas. Grantees can
      find areas designated as rural in the SCSEP Performance and Results Quarterly
      Progress Report (also known as “SPARQ”).

      Where applicable, the State must describe how it ensures that rural and urban
      areas are served equitably. If rural areas possess inadequate resources to meet
      program requirements (e.g., too few host agencies or employers, lack of
      transportation, etc.), the State Plan must indicate how grantees plan to address
      these needs, and include timelines.

  C. Specific Population Distribution. States must consider the relative distribution
     of eligible individuals afforded priority for service in OAA Section 518(b) and
     certain other population groups cited below. All grantees operating within the
     state must describe the recruitment and selection techniques for priority
     individuals.

      OAA Section 518(b) defines priority individuals as those who qualify based on
      one or more of the following criteria:

      1. Is 65 years of age or older; or
      2. a. has a disability;
         b. has limited English proficiency or low literacy skills;
         c. resides in a rural area;
         d. is a veteran or a spouse who meet the requirements of the Jobs for
             Veterans Act, 38 U.S.C. § 4215(a)(1);
         e. has low employment prospects;
         f. has failed to find employment after utilizing services provided under Title
             I of WIA; or
         g. is homeless or at risk for homelessness.

      Other populations identified in the statute as most in need, are defined in OAA
      Section 503(a)(4)(C)(i)(iv) as eligible individuals based on:

          •    “greatest economic need” (as defined in 20 CFR 641.140);
          •    minority status; and
          •   “greatest social need” (as defined in 20 CFR 641.140).

      Note: The statute also identifies eligible individuals who have limited English
      proficiency in section 518(b), but these are not included in this list because they
      are already identified in the list of priority individuals.

Section 10. Copies of Public Comments. The State Plan must include copies of any
public comments received, if applicable.

Attachment II: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2014/TEGL-8-14_Attachment-II_Acc.pdf

                                        ATTACHMENT II

              PY 2014 FEDERAL PROJECT OFFICER (FPO) LIST FOR SCSEP GRANTEES

           Grantee        Region       FPO Name               Phone                   E-Mail
Alabama                     III    Linda Lundy            (404) 302-5369   [email protected]
Alaska                      VI     Ingrid Nyberg          (415) 625-7947   [email protected]
Arizona                     VI     Latha Seshadri         (415) 625-7937   [email protected]
Arkansas                    IV     Marilyn Brandenburg    (972) 850-4617   [email protected]
California                  VI     John Jacobs            (415) 625-7940   [email protected]
Colorado                    IV     Rebecca Sarmiento      (972) 850-4621   [email protected]
Connecticut                   I    Suzanne Pouliot        (617) 788-0180   [email protected]
Delaware                     II    Christopher Ransome    (215) 861-5222   [email protected]
District of Columbia         II    Christopher Ransome    (215) 861-5222   [email protected]
Florida                     III    Linda Lundy            (404) 302-5369   [email protected]
Georgia                     III    Linda Lundy            (404) 302-5369   [email protected]
Hawaii                      VI     John Jacobs            (415) 625-7940   [email protected]
Idaho                       VI     John Jacobs            (415) 625-7940   [email protected]
Illinois                     V     Gary Lewis             (312) 596-5522   [email protected]
Indiana                      V     Gary Lewis             (312) 596-5522   [email protected]
Iowa                         V     Gary Lewis             (312) 596-5522   [email protected]
Kansas                       V     Gary Lewis             (312) 596-5522   [email protected]
Kentucky                    III    Linda Lundy            (404) 302-5369   [email protected]
Louisiana                   IV     Roseana Smith          (972) 850-4615   [email protected]
Maine                         I    Michael Hotard         (617) 788-0114   [email protected]
Maryland                     II    Christopher Ransome    (215) 861-5222   [email protected]
Massachusetts                 I    Suzanne Pouliot        (617) 788-0180   [email protected]
Michigan                     V     Gary Lewis             (312) 596-5522   [email protected]
Minnesota                    V     Gary Lewis             (312) 596-5522   [email protected]
Mississippi                 III    Linda Lundy            (404) 302-5369   [email protected]
Missouri                     V     Gary Lewis             (312) 596-5522   [email protected]
Montana                     IV     Bernie Cutter          (972) 850-4618   [email protected]
Nebraska                     V     Gary Lewis             (312) 596-5522   [email protected]
Nevada                      VI     John Jacobs            (415) 625-7940   [email protected]
New Hampshire                 I    Michael Hotard         (617) 788-0114   [email protected]
New Jersey                    I    Suzanne Pouliot        (617) 788-0180   [email protected]
New Mexico                  IV     Bill Martin            (972) 850-4635   [email protected]
New York                      I    Suzanne Pouliot        (617) 788-0180   [email protected]
North Carolina              III    Linda Lundy            (404) 302-5369   [email protected]
North Dakota                IV     Cynthia Wilson Green   (972) 850-4619   [email protected]
Ohio                         V     Gary Lewis             (312) 596-5522   [email protected]
Oklahoma                    IV     Felecia Blair          (972) 850-4643   [email protected]
Oregon                      VI     John Jacobs            (415) 625-7940   [email protected]
Pennsylvania                 II    Christopher Ransome    (215) 861-5222   [email protected]
Puerto Rico                   I    Michael Hotard         (617) 788-0114   [email protected]
Rhode Island                  I    Michael Hotard         (617) 788-0114   [email protected]
South Carolina              III    Linda Lundy            (404) 302-5369   [email protected]
South Dakota                IV     Bernie Cutter          (972) 850-4618   [email protected]
Tennessee                   III    Linda Lundy            (404) 302-5369   [email protected]
Texas                       IV     Kajuana Donahue        (972) 850-4613   [email protected]
Utah                        IV     Rebecca Sarmiento      (972) 850-4621   [email protected]
Vermont                       I    Suzanne Pouliot        (617) 788-0180   [email protected]
Virginia                     II    Christopher Ransome    (215) 861-5222   [email protected]
Washington                  VI     John Jacobs            (415) 625-7940   [email protected]
West Virginia                II    Christopher Ransome    (215) 861-5222   [email protected]
Wisconsin                    V     Gary Lewis             (312) 596-5522   [email protected]
Wyoming                     IV     Bill Martin            (972) 850-4635   [email protected]
American Samoa              VI     Janice Shordike        (415) 625-7943   [email protected]

9/25/2014

          Grantee                  Region       FPO Name              Phone                    E-Mail
Guam                                 VI     Janice Shordike       (415) 625-7943   [email protected]
Northern Mariana Islands             VI     Janice Shordike       (415) 625-7943   [email protected]
Virgin Islands                       I      Michael Hotard        (617) 788-0114   [email protected]


           Grantee                 Region       FPO Name              Phone                    E-Mail
AARP Foundation                      II     Christopher Ransome   (215) 861-5222   [email protected]
Asociación Nacional Pro
Personas Mayores                     VI     John Jacobs           (415) 625-7940   [email protected]
Associates for Training and          I      Suzanne Pouliot       (617) 788-0180   [email protected]
Development, Inc. (4ADT)
Easter Seals, Inc.                   V      Christopher Mendoza   (312) 596-5513   [email protected]
Experience Works, Inc.               III    Connie Taylor         (404) 302-5338   [email protected]
Goodwill Industries
International, Inc.                  II     Christopher Ransome   (215) 861-5222   [email protected]
Mature Services, Inc.                V      Gary Lewis            (312) 596-5522   [email protected]
National Able Network                 I     Suzanne Pouliot       (617) 788-0180   [email protected]
National Asian Pacific Center on     VI     John Jacobs           (415) 625-7940   [email protected]
Aging
National Caucus and Center on        II
Black Aged, Inc.                            Christopher Ransome   (215) 861-5222   [email protected]
National Council on the Aging,       II
Inc.                                        Christopher Ransome   (215) 861-5222   [email protected]
National Indian Council on           IV     Brie Burleson         (972) 850-4652   [email protected]
Aging
National Urban League                  I    Suzanne Pouliot       (617) 788-0180   [email protected]
Senior Service America, Inc.          II    Christopher Ransome   (215) 861-5222   [email protected]
SER - Jobs for Progress              IV     Amanda Denogean       (972) 850-4664   [email protected]
National, Inc.