SCSEP state plan deadline extension

Accessible letter PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2008/TEGL32-07acc.pdf

CLASSIFICATION
         EMPLOYMENT AND TRAINING                           SCSEP
      ADMINISTRATION ADVISORY SYSTEM                   CORRESPONDENCE SYMBOL
         U.S. DEPARTMENT OF LABOR                          OWI-DAS
            Washington, D.C. 20210                     DATE
                                                           June 25, 2008




ADVISORY: TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 32-07

TO:           SENIOR COMMUNITY SERVICE EMPLOYMENT
              PROGRAM GRANTEES

FROM:         BRENT R. ORRELL /s/
              Deputy Assistant Secretary

SUBJECT:      Guidance on Program Year (PY) 2007 State Plan Requirements


1. Purpose. To inform grantees of the extension of the due date for State Plans to
   June 30, 2008, and to clarify the status of current State Plans as of July 1, 2008.

2. References. Section 503 of the Older Americans Act (OAA), as amended by the 2006
   OAA Amendments, Public L. 109-365; 20 CFR 641.300-641.365, Senior Community
   Service Employment Program (SCSEP) Final Rule (April 9, 2004); Training and
   Employment Guidance Letter (TEGL) 25-06; Training and Employment Guidance
   Letter (TEGL) 16-07.

3. Background. Section 503 as amended by the 2006 OAA Amendments mandates
   significant changes to the SCSEP State Plan requirements. In order to receive SCSEP
   funds, Section 503(a)(1) of the law now requires the Governor or his/her designee to
   submit a State Plan that includes a four-year strategy for the statewide provision of
   community services and other authorized activities for eligible individuals under
   the SCSEP. The Department of Labor (Department) has issued two TEGLs relevant
   to the new state plan requirements in the OAA 2006 amendments. The first TEGL,
   TEGL 25-06, was issued on May 31, 2007, to delay implementation of the new State
   Plan requirements until PY 2008 due to the extensive changes in the law requiring




 RESCISSIONS:                                          EXPIRATION DATE: Continuing

grantees to submit plans including four-year strategies, rather than annual plans.
TEGL 25-06 also stated that to meet the requirement that state grantees have
approved state plans in place before grants can be awarded, the most recently
approved State Plans from PY 2006 would suffice for PY 2007 grant awards. The
second TEGL, TEGL 16-07, was issued on December 31, 2007, to inform the grantees
of the new state plan requirements mandated by the 2006 OAA amendments. It
established a due date of March 31, 2008, for submission of State Plans. This was
intended to allow sufficient time for the Department and the Administration on
Aging (AOA) to review and approve these plans as required before the PY 2008
grants would be awarded on July 1, 2008. This TEGL provides that confirmation.

Shortly after the TEGL was released on December 31, 2007, the Department realized
that the three month time period was insufficient for the grantees to complete the
new statutory planning requirements by March 31, 2008. The grantees were
informed in all-grantee conference calls and by e-mail that the time period would be
extended to June 30, 2008, and that a subsequent TEGL would be issued to confirm
the continued applicability of the currently approved state plans for purposes of
awarding PY 2008 grants on July 1, 2008.

We have discovered that the three month January – March 2008, time period is
inadequate for several reasons:
      • Lengthier timeframes are required to appropriately consult with all of the
         required stakeholders, develop a consensus plan, and obtain all the
         required signatures within the state;
      • The new state plan, with its focus on four-year strategies, involves, by its
         longer term strategic nature, a more complex process than the previous
         one-year plans required;
      • All grantees are conducting data validation for the first time during this
         same time period;
      • The HHS Administration on Aging, which is statutorily required to
         review SCSEP state plans, is in the process of having several states
         prepare their AOA two year plans in this same time frame;
      • The essential purpose and value of the four year state plan is to encourage
         thoughtful, deliberative planning that fully involves all relevant
         stakeholders in developing and providing appropriate services to low
         income seniors throughout each state, a purpose that can only be fulfilled
         with sufficient time allowed; and
      • Competing programmatic requirements make it impossible for states to
         do thorough and useful strategic plans in the original shorter time period.

We consider these factors to be outside the control of the states and have determined
that it would be unfair to state grantees, and potentially disruptive to program

   participants, to delay the award of PY 2008 grants to states affected by these factors.
   Therefore, we have determined that it is appropriate to extend states’ PY 2006
   coordination plans and to consider such plans as meeting the requirements of
   Section 503.

4. Guidance. Therefore, the Department extends the due date for PY 2007 State Plan
   submission to June 30, 2008. State and territorial grantees must submit their State
   Plans to their Federal Project Officer. Official approval of the plans will follow
   review by the Department and the HHS Administration on Aging. In order to
   comply with the requirement that states and territories have an approved
   coordination plan in order to be eligible for PY 2008 funding, the Department will
   consider the state’s current PY 2006 coordination plan to be extended until
   October 31, 2008.

5. Inquiries. Questions should be directed to your regional Federal Project Officer.