Extensions and revisions for Welfare-to-Work grants

U. S. Department of Labor
Employment and Training Administration
Washington, D.C. 20210
CLASSIFICATION
WtW
CORRESPONDENCE SYMBOL
OAS
DATE
March 8, 2001
TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 15-00
TO: STATE WELFARE-TO-WORK CONTACTS
STATE WORKFORCE LIAISONS
for
FROM: LENITA JACOBS-SIMMONS
Deputy Assistant Secretary
SUBJECT: Guidance and Instructions for Requesting an Extension and Related Revisions to Welfare-to-Work Formula and Competitive Grants and Welfare-to-Work Formula State Plans RESCISSIONS: None EXPIRATION DATE: Continuing

1. Purpose. To provide guidance to Welfare-to-Work (WtW) Formula and Competitive
   grantees on the provision of the Department of Labor Appropriations Act, 2001, which allows for a voluntary extension of up to five years from the date of award for all WtW grants. It also provides guidance on several other related issues.
2. Authorities and References.
   a. Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (Pub. L.104-193); Balanced Budget Act of 1997 (Pub. L. 105-33) amending Title IV-A of the Social Security Act. b. Welfare-to-Work and Child Support Amendments of 1999 (1999 Amendments) (introduced as Title VIII of H.R. 3424 and enacted as part of the Consolidated Appropriations Act for FY 2000 (Pub. L. 106-113)). c. Department of Labor Appropriations Act, 2001 (Pub. L. 106-554). d. WtW Regulations, 20 CFR Part 645, Final/Interim Final Rule published at 66 Fed. Reg. 2690 (January 11, 2001), effective date April 13, 2001.

e. WtW Planning Guidance and Instructions for Submission of Annual State Plans, Fiscal Year 1999 WtW Formula Grants (Training and Employment Guidance Letter (TEGL) 3-98), published July 30, 1998. f. WtW Competitive Grants; Notice of Availability of Funds; Solicitation for Grant Applications, 62 Fed. Reg. 67902 (December 30, 1997); 63 Fed. Reg. 18445 (April 15, 1998); and 64 Fed. Reg. 4009 (January 26, 1999). g. Use of America’s Workforce Network (AWN) Logo (Training and Employment Information Notice No. 7-00), published October 26, 2000. h. WtW/Workforce Investment Act (WIA) Questions and Answers, Question #6 (concerns the revision of WtW State Plan to reflect a change in geographic configuration -- see http://wtw.doleta.gov/q&a/wiaquestions.asp).

3. Background. The WtW Program, authorized by Congress under the Balanced Budget Act of
   1997, facilitates the placement of hard-to-employ welfare recipients and certain noncustodial parents into transitional employment opportunities which will lead to lasting unsubsidized employment and self-sufficiency. The 1999 Amendments removed the requirement that long-term Temporary Assistance for Needy Families (TANF) recipients meet additional barriers to employment in order to be eligible for WtW, and provided for other changes to the WtW Program. The Department of Labor Appropriations Act, 2001, signed into law on December 21, 2000 as part of the Consolidated Appropriations Act of 2001, includes, along with the Department of Labor’s Fiscal Year (FY) 2001 appropriations, the authority to extend the period in which funds can be spent in the WtW grants program. Under this authority, all WtW grantees, both competitive and formula, are eligible to extend the period of performance of their grants up to five years from the date of grant award. As amended, section 403(a)(5)(C)(viii) now reads as follows: DEADLINE FOR EXPENDITURE -- Any entity to which funds are provided under this paragraph shall remit to the Secretary of Labor any part of the funds that are not expended within 5 years after the date the funds are so provided. The guidance in this TEGL is intended to provide instructions on how to implement this amendment. States choosing to extend their grant period will also have up to two more years to meet their matching fund commitments. This guidance has two main sections:
   • Grant and State Plan modification instructions applicable to WtW Formula Grantees (FY 98 and FY 99), including the new modification language regarding AWN; and

• Grant Modification instructions applicable to WtW Competitive Grantees (all rounds of competition).

4. Information for WtW Formula Grantees. The following is an overview of information
   about modifications of WtW formula grants. Please refer to Attachment I (Grant and State Plan Modification Instructions for WtW Formula Grantees). FY 98 and/or FY 99 WtW formula grantees may submit a grant and State Plan modification request for an extension of the expiration date (as a result of the Department of Labor Appropriations Act, 2001) and must submit a modification to the State Plan to reflect any geographic changes in local areas (as a result of the designation of local areas under WIA) and/or revision of definitions as follows: a. Extension of the Grant Period. A State’s WtW Formula Grant can be modified to extend the expiration date for up to 24 months if the State wishes to have additional time to complete its grant activities. Formula grants were originally awarded for a period of three years. The provision in the Department of Labor Appropriations Act, 2001, would allow an additional two years, not to exceed five years from date of award. States may elect to extend one FY’s grant or both. A letter requesting such modification(s) must be submitted to the Grant Officer. The duration of the extension requested should reflect an analysis of grant performance to date as well as the availability of existing funds to operate the grant during the requested extended period. The request for an extension of the grant period must incorporate a new grant termination date. Any extension of the grant period would also allow for additional time for the expenditure and reconciliation of the State WtW formula grantee’s match requirements. b. Change in Geographic Configuration of Local Areas. Whether or not a State chooses to request an extension, the State must request a modification of its State Plan if, due to the implementation of WIA, the geographic configurations of local areas and WtW formula allocations are different than the geographic configuration of service delivery areas (SDAs) and WtW formula allocations provided by the State in the approved FY 98 and/or FY 99 WtW plan. The modification must identify the affected Local Workforce Investment Areas and the adjusted amount of WtW funds allocated to those areas. c. Revision of State Plan Performance and Expenditure Goals. Revised performance goals are needed for the Department of Labor to assess WtW Program performance as required by the Government Performance and Results Act (GPRA). Therefore, when submitting a request for a grant modification to extend the period of performance, a State grantee must also provide revised performance goals as part of a separate State Plan modification. This will include cumulative quarterly planned enrollments and expenditures as well as final expected outcomes for: (a) placements into unsubsidized jobs; (b) percentage of participants retained for six months in unsubsidized jobs; and (c) percentage of wage gains. These goals must reflect performance to date as well as the extended operational period.

d. Revision of Definitions. The 1999 Amendments introduced revised eligibility criteria to make the WtW Program more flexible in serving the targeted population. Congress did not define a number of new terms that are now contained in the WtW eligibility criteria for long-term welfare recipients and certain noncustodial parents. The Employment and Training Administration (ETA) has followed the position that operating entities establish their own definitions to the greatest extent possible in the implementation of WtW and now in the implementation of the 1999 Amendments. Whether or not a State chooses to request an extension, or whether or not the geographic configuration of its local areas has changed, if a WtW grantee has developed or revised definitions as a result of the enactment of the 1999 Amendments, such information must be submitted in a modification of the State Plan. e. Use of AWN’s Logo. The Department of Labor is working with partners and stakeholders in the workforce development system to create America’s Workforce Network (AWNK). AWN is the brand name for the nationwide network that provides information and services to help employers find qualified workers and to help people manage their careers. The AWN brand name establishes a national identity that connects the workforce services available throughout the nation. The AWN brand name supports the establishment and awareness of State and local identity and does not require changes to State or local brands or logos. The Network demonstrates to employers that there is a workforce development system that can meet their needs and informs the general public about available AWN services through the One-Stop system. WtW formula grants will be modified separately to confirm that the grantee agrees to use the brand name and logo on all public materials such as statements, press releases, brochures, advertisements, reports, products, web pages and other documents describing projects or programs funded in whole or in part with ETA federal funding. Many grantees in the workforce development system have already incorporated the use of the brand name and logo in their grant materials. Language which will be incorporated in WtW formula grants as a separate modification action can be found in Attachment II of this TEGL. Additional information about the AWN brand name logo can be found in Training and Employment Information Notice No. 7-00, which was issued October 26, 2000, or online at http://www.usworkforce.org. Complete instructions for the submission of an extension request and the updated information required to amend the current formula State Plans are included as Attachment I (Grant and State Plan Modification Instructions for WtW Formula Grantees).

5. Information for WtW Competitive Grantees. Any WtW Competitive Grantee may submit
   a modification request for a no-cost extension (as a result of the Department of Labor Appropriations Act, 2001) as follows:

a. Extension of the Period of Performance. A WtW competitive grantee may request a no-cost extension of up to five years (60 months) after the grant’s award date if the grantee needs additional time to complete its grant activities. The extension request should include an analysis of grant performance to date, and a description of how the additional time will benefit the delivery of services to WtW participants. The request should also document the availability of administrative funds to operate the grant during the requested extension period. Note that the 15% cap on administrative expenditures is not affected by the extension and remains applicable for WtW grants. b. Revision of Performance and Expenditure Goals. Revised performance goals are needed for the Department of Labor to assess WtW Program performance as required by GPRA. When submitting a request for a grant modification to extend the period of performance, a grantee must also provide revised performance and expenditure goals At a minimum, the grantee must provide projected quarterly cumulative enrollment and expenditure targets, as well as final expected outcomes for placements in unsubsidized employment, retention rate at six months and increase in earnings. The quarterly goals must reflect performance to date as well as for the period covered by the requested extension. If the projected performance goals are not based on past performance, justification for the new projections should be provided. c. Revision of Definitions. Many WtW competitive grantees applied for funding “in conjunction with” a Private Industry Council (now Local Board) or political subdivision. In implementing the WtW Program, Local Boards in cooperation with the States arrived at definitions of terms to which WtW competitive grants were subject, for example: “characteristics of long-term welfare dependence.” As a result of the 1999 Amendments, most Local Boards will have developed or revised some of their definitions which are necessary for determining eligibility, such as “having difficulty making child support payments.” WtW competitive grantees that applied for funding with a Local Board are advised to coordinate their eligibility and other procedures with the appropriate Local Boards to ensure that they are in compliance with WtW requirements. The instructions for extensions of the period of performance of WtW Competitive Grants may be found in Attachment III (Grant Modification Instructions for WtW Competitive Grantees).

6. Action. Requests for extensions and related revisions to WtW formula and competitive grants
   and WtW State Plans must be submitted in accordance with the attached instructions.
7. Inquiries. Inquiries on this TEGL and the attachment(s) should be directed to your
   Grant Officer Technical Representative.
8. Attachments.
   I -- Grant and State Plan Modification Instructions for WtW Formula Grantees II -- Information About the America’s Workforce Network Logo III -- Grant Modification Instructions for WtW Competitive Grantees

Official attachment PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2001/TEGL15-00Attach1.pdf

Attachment I
GRANT AND STATE PLAN MODIFICATION INSTRUCTIONS
FOR
WELFARE-TO-WORK FORMULA GRANTEES
Instructions for Modification of State Formula Grants to Extend the Grant Period and Instructions for Modification of the State Plan Narrative. Part I includes instructions on the information necessary for the Grant Officer to extend the period of performance of FY 98 and FY 99 State formula grants for up to a total of five years from the date of grant award, as allowed by the Department of Labor Appropriations Act, 2001. Part II of the instructions is for modifying the narrative portion of the State Plan to reflect the extended period of performance and for other revisions and additions necessitated by the implementation of the WtW and Child Support Amendments of 1999 (The 1999 Amendments), the implementation of the Workforce Investment Act (WIA), and the requirements of the Government Performance and Results Act (GPRA). I. MODIFICATION TO GRANT TO EXTEND THE GRANT PERIOD. A. Explanation. The Department of Labor Appropriations Act, 2001, provides authority for all FY 98 and FY 99 WtW formula grants to extend their grant period by up to two years from the current date of expiration to a potential maximum period of performance of five years from the date of grant award. Such an extension of the grant period also allows for additional time for the expenditure and reconciliation of the State WtW grantee’s match requirement. States may request a grant modification to extend the FY 98 grant, the FY 99 grant, or both. Some of the FY 98 grants will reach the end of their original period of performance starting in February, 2001. These grants were awarded on a staggered basis so the expiration dates will vary between February and September, 2001. The FY 99 grants will reach their expiration dates at varying times during FY 2002 (October1, 2001, to September 30, 2002). Priority attention should be given to the FY 98 grants which are due to expire shortly and have large balances of unexpended funds. An extension of the period of performance would provide the needed operating time to serve participants with the remaining grant funds. B. Information Required for a Grant Extension: Letter of Request to Grant Officer. A request for a grant extension may be made at any time. However, the request must be submitted no later than sixty (60) days before the current expiration date of the grant. [Please note: For those States which have already submitted requests for grant extensions under the “Advance Instructions for FY 1998 and FY 1999 Formula Grants” made available through your Grant Officer Technical Representative (GOTR), in many cases the State must still modify its State Plan as directed below. The State Plan modification request must be submitted within sixty (60) days of the date of this TEGL.]

To request an extension of its FY 98 or FY 99 WtW grant (or both), a State must submit a grant modification request letter addressed to the Grant Officer (E. Fred Tello). An original signature copy and one copy of the request for a grant extension modification and/or a State Plan modification should be mailed to the following address: Office of Welfare-to-Work U.S. Department of Labor - ETA 200 Constitution Avenue NW Room: N-4666 Washington, DC 20210 Attention: Formula Grant Extension Modification A copy of the request should be mailed concurrently to your GOTR. The letter must be signed by an authorized signatory official for the State’s WtW grant and must include the following information for each grant for which an extension of the grant period is being proposed:

1. Current Grant Recipient Agency Name and Address (if different from State letterhead);
2. Department of Labor Grant Number indicated in current grant document(s);
3. Current Grant Expiration Date; and
4. Requested Grant Expiration Date (Note: The request may not exceed two-years from the
   current expiration date of the grant).
   II. MODIFICATION OF STATE FORMULA PLAN NARRATIVE
   A. Revision of Performance Goals.
   Planning Guidance Requirement:
   “List the performance goals and outcomes the State intends to achieve in serving the eligible participants in the WtW Program including: (a) placement in unsubsidized jobs; (b) duration of such placement; and (c) increase in earnings. The performance goals and outcomes should be expressed in measurable, quantifiable terms to the greatest extent possible.” [TEGL 3-98, Section I.A.4, Program Design] In our original Planning Guidance, cited above, we asked WtW formula grantees to submit certain measurable program goals and outcomes. Some States responded by providing the requested data in their State Plans, while other States indicated that they were waiting for additional guidance from the Secretary of Labor before submitting that specific data. Such guidance was intended to address the criteria for performance bonuses in FY 2000. Because the Department of Labor Appropriations Act, 2001, eliminated the funds available for performance bonuses, no bonus guidance will be issued. However, WtW program outcomes are needed to demonstrate the success of the program in serving eligible individual participants. Therefore, this information remains pertinent and relevant for ETA to assess WtW program performance as required by

GPRA, as well as for the Department of Health and Human Services (HHS) evaluation of the WtW Program. The GPRA goal for FY 2001 for the WtW Program is: “Of those Welfare-to-Work participants placed in unsubsidized employment, 66% will remain in the workforce for six months with a 6% average earnings increase by the second consecutive quarter following the placement quarter.” Enrollment Goals In conjunction with a request to extend the period of performance of the grant, we are requiring that States submit goals for the projected number of participants to be served in the remaining performance period of the grant, including the extended time requested. This is necessitated by prudent management of the grant program. We recognize that States may already be tracking such goals. Revised Plan Requirement for Performance Goals As part of a request for an extension of its WtW grant, any State which has not already done so must submit performance outcomes which, at a minimum, reflect the information requested in the planning guidance: (a) placement in unsubsidized jobs; (b) duration of such placement; and (c) increase in earnings (expressed as a percentage). This information must include the State’s expected outcomes for the end of the extended grant period, as well as identification of performance to date. Please submit a revised estimate of cumulative quarterly plan of participants to be served for each future quarter of the grant starting with the quarter at the time of application for an extension of the grant period. This should include all quarters of the requested extended grant period. Note: States may submit a chart with combined enrollment and expenditure goals for each quarter. B. Revision of Cumulative Quarterly Expenditure Goals. Planning Guidance Requirement “The State should submit an estimate of expenditures of WtW formula grant funds for each quarter of each fiscal year covered by the plan by percentage or dollar amount.” [TEGL 3-98, Section IV, Funding] In the original planning guidance, cited above, we requested that States submit an estimate of expenditures of WtW formula grant funds for each quarter of each fiscal year. This is an opportunity for grantees to revise current expenditure plans as well as submit new quarterly plans for an extended grant period. States should take into account the level of expenditures to date and the length of time needed to carry out the grant.

Revised Plan Requirement for Cumulative Quarterly Expenditure Goals Please submit a revised estimate of cumulative expenditures for each future quarter of the grant starting with the quarter at the time of application for an extension of the grant period. This must include all quarters of the requested extended grant period. For example: Your State submits an application for an extension of its FY 1998 grant in July, 2001, for a period of two years. Your submittal must include a quarterly cumulative expenditure plan for the quarter beginning July 1, 2001, and each subsequent quarter through the last quarter of the requested extended period of performance. Your State must submit this revised cumulative expenditure plan using dollar amounts only. Note: States may submit a chart with combined enrollment and expenditure goals for each quarter. C. Change in Geographic Configuration of Local Areas Due to the Implementation of WIA. Planning Guidance Requirement: “Within State Distribution of Funds: Describe the formula factors, including the weights assigned to each factor, used by the State to allocate not less than 85 percent of the amount of grant funds among the Private Industry Councils (PICs) in the State as well as the timeline for the allocation to PICs. Provide a listing of the allocations the State will make to each substate area.” (emphasis added) [TEGL 3-98, Section I.B, Within State Distribution of Funds] WtW funds were distributed to PICs in accordance with the WtW law and regulations in effect at the time of grant award. The subsequent enactment of WIA called for the development of Local Workforce Investment Areas and local workforce boards, which replaced the Service Delivery Areas (SDAs) and PICs under the Job Training Partnership Act (JTPA). If the geographic configurations of local areas changed under WIA implementation, the State entity that administers the WtW grant must ensure that funds are appropriately redistributed among Local Workforce Investment Areas. Based on the elements in the State’s distribution formula outlined in the WtW formula plan, the State must determine what, if any, adjustments to local area allocations are necessary. Adjustments, to the extent needed, should be made only out of funds that are unexpended or unobligated at the local level. Revised Plan Requirement for Change in Geographic Configuration If the geographic configuration of local areas designated under WIA and WtW formula allocations for local areas are different than those provided by the State in the approved FY 98 and/or FY 99 WtW formula plan, then the State should submit a revision to this section of the plan. The revision should identify the newly designated local workforce investment areas and the adjusted amount of WtW funds allocated to those areas. D. Revision of Definitions.

Planning Guidance Requirement:
“...Specify any additional characteristics associated with, or predictive of, long term welfare dependence which have been identified by the State, in consultation with the operating entity, which will be used in determining eligibility under the thirty percent provision.” [TEGL 3-98, Section I.A.6, Program Design] The 1999 Amendments introduced revised eligibility criteria to make the WtW program more flexible in serving the targeted population. Congress did not define a number of new terms that are now contained in the WtW eligibility criteria for long-term welfare recipients and certain noncustodial parents. ETA has followed the position that operating entities establish their own definitions to the greatest extent possible in the implementation of WtW and now in the implementation of the 1999 Amendments. In some cases in defining terms, such as “unemployed,” ETA has adapted existing definitions in order to be consistent with WIA where possible. The WtW Final Rule and Interim Final Rule, issued on January 11, 2001, adds a new section 645.125 on the governance of the WtW Program by State and local operating entities to emphasize this flexibility. Revised Plan Requirement for Definitions ETA therefore requests that States submit, as part of this modification package, the definitions agreed upon for the following terms:

1. “Underemployed” (as defined by the State in consultation with Local Boards and WtW
   competitive grantees); and
2. “Having difficulty paying child support obligations” (as defined by the State in
   consultation with Local Boards, WtW competitive grantees and the State Child Support Enforcement (IV-D) agency). States may also submit any other definitions that may have been added or revised subsequent to the approval of their current State Plan.

Official attachment PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2001/TEGL15-00Attach2.pdf

Attachment II
INFORMATION ABOUT THE
AMERICA’S WORKFORCE NETWORK LOGO
America’s Workforce Network is the brand name for the nationwide network of workforce development organizations that provide information and services to help employers find skilled workers and people manage their careers. State WtW grantees will receive under separate cover a grant modification document, for signature, to incorporate the following: “The official name for the nationwide system for providing employment and training through the Workforce Investment Act partnerships and various other federally-sponsored programs is “America’s Workforce NetworkSM.”(or AWNTM). To achieve the goals of this grant, it is important that the public has a quick and easy method of identifying that the projects or programs participated are part of America’s Workforce Network. To provide this information to the public, the Grantee agrees to place the America’s Workforce Network logo, in accordance with the U.S. Department of Labor’s guidelines for such use, on all public materials such as statements, press releases, brochures, advertisements, reports, products, web pages, and other documents describing projects or programs funded in whole or in part with Federal funding. When the America’s Workforce Network logo is used, the Grantee may accompany it with the following statement: “[Program Grantee Agency Name] is a Proud Member of America’s Workforce NetworkSM.” The Grantee shall not use the America’s Workforce Network logo in any manner that would imply that the Department of Labor endorses a commercial product, service, or activity or that material of a nonofficial nature represents the U.S. Department of Labor. The Grantee shall include Grant/Contract Language included in these guidelines in its subgrants to local workforce investment areas and may require that other subgrantees or contractors use the America’s Workforce Network brand identification.” Included in the package to be sent under separate cover will be a Style Guide which will provide additional guidance to grantees on the use of the America’s Workforce Network name, logo and accompanying slogan.

Official attachment PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2001/TEGL15-00Attach3.pdf

Attachment III
GRANT MODIFICATION INSTRUCTIONS
FOR
WELFARE-TO-WORK COMPETITIVE GRANTEES
Instructions for Modification of WtW Competitive Grants to Extend the Period of Performance. Part I includes instructions on the information necessary for the Grant Officer to extend the period of performance of WtW Competitive grants for up to five years as allowed by the Department of Labor Appropriations Act, 2001. Part II of the instructions is for other revisions and additions to the grant scope of work as necessitated by the implementation of the WtW and Child Support Amendments of 1999 (the 1999 Amendments), the implementation of the Workforce Investment Act (WIA), and the requirements of the Government Performance and Results Act (GPRA). I. MODIFICATION TO GRANT TO EXTEND THE PERIOD OF PERFORMANCE A. Explanation. The Department of Labor Appropriations Act, 2001, provides authority for all WtW competitive grants to extend their period of performance for up to five years from the date of award. Some Round One WtW competitive grants will reach the end of their original period of performance in June, 2001. B. Information Required for a No-Cost Extension: Letter of Request to Grant Officer. To request a modification to extend the period of performance of a WtW competitive grant, a grantee must submit a grant modification request letter to the Grant Officer (Jim Stockton). The letter must be signed by an authorized signatory official for the WtW grant, and must be submitted through the grant’s Grant Officer Technical Representative (GOTR) for review. The letter must include the following information:

1. Current Grant Recipient Agency Name and Address (if different from letterhead);
2. Department of Labor Grant Number indicated in current grant document(s);
3. Current Grant Expiration Date;
4. Requested Grant Expiration Date (Note: The request may not exceed five years from the
   date of award of the grant);
5. An analysis of the grant performance to-date with a description of how the additional time
   requested will benefit the delivery of services to WtW participants; and
6. A revised grant budget reflecting the availability of administrative funds to operate the grant
   during the requested extended grant period.
   An original signature copy of the letter must be sent to the GOTR for the grant for their review and approval. The GOTR will then forward the request to the Grant Officer for execution.

II. UPDATE OF GRANT SCOPE OF WORK
A. Revision of Performance and Expenditure Goals.
In the Round One WtW Competitive Grant SGA (Federal Register Vol. 62, No. 249, December 30, 1997), applicants were asked to provide “a completed quarterly implementation schedule showing the number of participants, enrollments in allowable activities, placements in unsubsidized employment and terminations” as well as a “Quarterly expenditure plan which identifies the planned cumulative expenditure of grant funds by Fiscal Year quarter for the planned period of performance of the project. Expenditures must be identified by grant activity.” Recommended formats were provided as part of the SGA. In the Round Two and Three SGAs (published in the Federal Register on April 26, 1998, and January 26, 1999, respectively), applicants were asked to provide “an implementation schedule showing the number of participants, enrollments in allowable activities, placements in unsubsidized employment and terminations over the life of the grant.” Before approving a request for an extension of a WtW competitive grant operational period, the Grant Officer will require an estimate of enrollments and expenditures of WtW competitive grant funds for each quarter of the grant through the requested extended grant period, starting from the date of award. Grantees must take into account past performance, the level of expenditures to date and the length of time needed to complete grant activities in developing their quarterly enrollment and expenditure plans. This information is relevant for ETA to assess WtW Program performance as required by GPRA as well as for the Department of Health and Human Services (HHS) evaluation of the WtW Program. The GPRA goal for FY 2001 for the WtW Program is: “Of those Welfare-to-Work participants placed in unsubsidized employment, 66% will remain in the workforce for six months with a 6% average earnings increase by the second consecutive quarter following the placement quarter.” Revised Requirement for Performance and Expenditure Goals Please submit a revised estimate of cumulative expenditures and enrollments for each quarter of the grant starting with the date of award through the requested extension period. Note: Grantees may submit a chart with combined enrollment and expenditure goals for each quarter. In addition, grantees must submit revised projected outcomes for (1) number of participants placed in unsubsidized jobs; (2) percentage of participants retained for six months in unsubsidized jobs; and (3) percentage of wage gains. These projected outcomes must reflect the grantee’s expected outcomes for the end of the extended period of performance, as well as identification of performance to date.

B. Revision of Definitions.
Grantees should be aware that State and Local Workforce Investment Boards may be developing programmatic definitions resulting from recent changes to the WtW program. The 1999 Amendments introduced revised eligibility criteria to make the WtW program more flexible in serving the targeted population. Congress did not define a number of new terms that are now contained in the WtW eligibility criteria for long-term welfare recipients and certain noncustodial parents. ETA has followed the position that operating entities establish their own definitions to the greatest extent possible in the implementation of WtW and now in the implementation of the 1999 Amendments. In some cases in defining terms, such as “unemployed”, ETA has adapted existing definitions in order to be consistent with WIA where possible. The WtW Final Rule and Interim Final Rule, issued on January 11, 2001, adds a new section 645.125 on the governance of the WtW program by State and local operating entities to emphasize this flexibility. Please note that ETA is requesting that States submit the definitions agreed upon for the following terms:

1. “Underemployed” (as defined by the State in consultation with Local Boards and WtW
   competitive grantees); and
2. “Having difficulty paying child support obligations” (as defined by the State in consultation
   with Local Boards, WtW competitive grantees and the State Child Support Enforcement (IV-D) agency). States have also been requested to submit any other definitions that may have been added or revised subsequent to the approval of their State Plan. Competitive grantees should be aware that States and Local Boards should be informing competitive grantees of changes to these definitions, and that the definitions arrived at by the appropriate State and Local Boards will be binding for said competitive grantee.