References. a. The Job Training Partnership Act (JTPA), as amended; b. Goals 2OOO: The Educate America Act, signed into law by the President on March 31, 1994; c. JTPA Interim Final Rules, as published in the Federal Register on December 29, 1992; d. Amendments to the JTPA Interim Final Rules, as published in the Federal Register on June 3, 1993; e. Training and Employment Guidance Letter No. 2-93 (December 21, 1993): "JTPA Titles II-A, II-C, and III Allotments for Program Year (PY) 1994; Title II-B Allotments for Calendar Year (CY) 1994; and Wagner-Peyser Preliminary Planning Estimates for PY 1994"; f. Training and Employment Information Notice No. 6-93 (July 30, 1993): "Instructions for the Title II Job Training Partnership Act (JTPA) Quarterly Financial Status Report" and Change 1 to this TEIN (January 13, 1994); g. Training and Employment Information Notice No. 39-93 (March 4, 1994): "Announcements of JTPA Summer Enrichment Training Sites and Schedule"; h. Training and Information Notice No. 40-93 (March 17, 1994): "Cooperation in Implementing AmeriCorps Service Programs;" i. Training and Employment Information Notice No. 33-92 (June 1, 1993): "Child Labor Restrictions Applicable to Youth Participants in Job Training Partnership Act (JTPA) Funded Programs." Background: The CY93 SYETP constituted a major initiative of President Clinton, Secretary of Labor Robert B. Reich, and Secretary of Education Richard W. Riley to enhance and enrich the summer program in all aspects. Particular focus was placed on the education component of the program and the connection between work experience and education. The aim, as President Clinton stated during his address to the "Summer Challenge" Conference on April 13, 1993, is to "remove the artificial line between work and learning." The 1994 summer program expands and refines this primary and overarching challenge. Allotments/Allocations: States were apprised of their 1994 summer program allotments via TEGL No. 2-93. The Employment and Training Administration (ETA) understands that all SDAs have been given their CY94 allocations. Additional funding for the CY94 summer program is not expected. Findings of the Study of the 1993 SYETP: ETA engaged Westat Inc. to conduct a study of the 1993 summer program. Westat conducted onsite case studies at 50 SDAs. These SDAs accounted for approximately 26 percent of the national enrollment. The onsite work was supplemented by a mail questionnaire responded to by 631 SDAs. The data from this survey firmly reinforce the onsite findings. Westat's Final Report will be forthcoming shortly and States will be sent copies. A summary of Westat's major interim findings follows: a. Work Experience Component: (1) The youth were engaged in "real work"; there was virtually no evidence that youth were assigned to "make-work" jobs. (2) Both the youth and worksite supervisors overwhelmingly viewed the work component as a productive and satisfying experience. (3) The youth demonstrated a strong work ethic, as evidenced by a low dropout rate and worksite supervisors' observations. (4) The youth were generally well-supervised; responses to the national questionnaire indicated an average ratio of four participants per worksite supervisor. (5) The youth acquired general work skills--e.g., responding to supervision; working as a member of a team. b. Education Component: (1) The education component experienced a notable improvement over prior years in terms of the number and percentage of participants enrolled in education activities. (a) Responses to the national questionnaire disclosed that 41 percent of participants received some sort of educational service. (This contrasts to the 33 percent estimated immediately after the conclusion of the CY93 program.) (b) Of the 50 SDAs visited, only 27 percent of the participants received some sort of educational service. This finding tends to confirm a pattern first detected by an analysis of the end-of-program reports: those SDAs (both urban and suburban) with large enrollments provided less educational services than other SDAs. (Of course, there are notable exceptions to this trend.) Westat's sample included a high number of SDAs with large enrollments, which probably accounts for the difference in percentages between the sample SDAs and the nation as a whole. (c) While Westat offered no judgement on the types of educational activities reported and observed, ETA's review of Westat's data summary and the results of Regional Office monitoring leads us to believe that, in some instances, SDAs took a somewhat elastic view of which activities they considered "educational." (2) The median number of hours spent in the education component was 75, with the hours ranging widely among the SDAs from 9 to 240. (3) The education component was rich in its diversity, in terms of both contents and the methods of instruction. On the whole, this is a very positive finding. However, also see item (1) (c) above. (4) Most of the education components incorporated important elements which are often missing during the regular school year--small classes, individualized attention, and more freedom for instructors to utilize curricula and teaching methods which are tailored to participants' needs. The average ratio of students to teachers was 11:1, obviously much lower than in the regular classroom setting. (5) Youth opinions of the education components were generally favorable, although, not surprisingly, most preferred work over academic instruction. (6) There was little substantive interaction between the work and education components. (7) There was little evidence of information exchange about participants' performance between the SDAs and the local school systems once the program ended. c. Community Perceptions: (1) Public awareness of the benefits of the summer program was quite limited. (2) However, those public officials, community leaders, business owners, parents, and clergy who were at least moderately aware of the program, had generally favorable perceptions. Those expressing a negative perception of the program based it mainly on negative publicity surrounding the early years of the program. For the most part, Regional Office monitoring tended to confirm Westat's findings. The Regional Offices found only isolated and relatively minor instances of infractions of eligibility determinations and accepted payroll procedures. Judging from this summary of Westat's findings, it should be clear that any enrichments to the summer program rest on a solid base. Based on ETA's analysis of Westat's findings and the policy emphases it has adopted, ETA has identified areas where we feel these enrichments should be made. These will be covered in subsequent sections of this TEGL. Legislative Purpose: For the sake of overall perspective, it may be helpful to reiterate the legislative purposes of the SYETP (Section 251): "It is the purpose of programs assisted under this part-- "(1) to enhance the basic educational skills of youth; "(2) to encourage school completion or enrollment in supplementary or alternative school programs; "(3) to provide eligible youth with exposure to the world of work; and "(4) to enhance the citizenship skills of youth." Goals and Objectives" The Department of Labor's vision of the summer program is of a program which plays an important role in Secretary Reich's "First Jobs/New Jobs/Better Jobs" strategy--a program where new entrants to the labor force and those with short job histories: a. build and refine a strong foundation of workplace competencies and discipline; and, b. gain an abiding appreciation of the inextricable connection between work and learning ("life-long learning") which is so critical to a long-term attachment to, and success in, a rapidly changing labor market. It is this vision which has guided the development of the goals and objectives for the 1994 summer program: NATIONAL GOALS a. Ensure that youth receive benefit of meaningful work experience which: (1) demonstrates the value of the work to be performed to the individual, the employers, her/his community, and her/his city or county and State; (2) assists the youth in acquiring basic work competencies and discipline--e.g., punctuality and reliability with regard to attendance; responding to supervision and direction; cooperating with co-workers in team efforts; delivering quality work products and services; (3) impresses upon youth that they are personally responsible for rewards or sanctions which may be dispensed for good or bad performance on the job; (4) offers a workplace context in which work and learning are integrated; the SCANS foundations and competencies--or reasonable variations thereof--should be used in identifying what is to be learned in the workplace. [A summary of SCANS foundations and competencies is attached to this TEGL.] b. Further facilitate the integration of work and learning by ensuring that any classroom-based learning which is offered conveys the real work applications of the academic disciplines the youth are studying. The SCANS foundations and competencies--or reasonable variations thereof--should be considered in developing curricula for classroom-based learning. c. Assist youth in adopting the attitudes, values, and behavior patterns which are vital to success in the classroom, on the job, and as a citizen. d. Counteract the erosion of basic educational skills associated with school vacations and strive to increase the level of educational skills, particularly in reading, writing, and mathematics. e. Enhance working relationships with local school systems to ensure a two-way flow of relevant information about participants' progress and follow-up services which may be needed. f. Strengthen linkages with the JTPA Title II-C program and other available programs to preserve and enhance educational and work maturity gains achieved by the Title II-B program. g. Enlist the involvement of the private sector to: (1) increase the number of unsubsidized job opportunities available to disadvantaged youth; (2) expose youth to work in a private sector setting. h. Enroll the maximum number of youth possible and minimize the amount of unplanned carry-forward, consistent with sound financial practices and fiscal integrity. NATIONAL OBJECTIVES a. Provide educational services to at least 50 percent of participants nationally; such services may be delivered in classroom setting or in a workplace context, or both, but must be documented. b. Achieve a ten percent increase in the number of private sector unsubsidized jobs filled by disadvantaged youth; c. Achieve an expenditure level of 90 percent of total availability (i.e., new allocation plus carry-in from CY93). The amount transferred to Title II-C will be subtracted from total availability when computing the percentage of funds expended. What follows is an elaboration of some of the goals and discussions of other issues which have arisen. However, ETA considers the legislative purposes of the Act and all the goals and objectives enunciated herein as equally deserving of achievement. Work Experience: All available evidence indicates that a large majority of SDAs are administering effective work experience components. Those States, SDAs, and worksite operators are commended for their efforts and accomplishments. To further enhance this component, all SDAs should ensure that all worksites introduce and/or reinforce the rigors, demands, rewards, and sanctions associated with holding a job. Participants should clearly understand basic employment rules and requirements and employer expectations prior to starting on the job--including the necessity to perform well in a structured educational setting as well as on the job. SDAs are encouraged to consider the use of written employer- employee agreements or "contracts" to emphasize both employer and participant responsibilities and avert misunderstandings. Infraction of rules should be swiftly dealt with in accordance with local policies and procedures. If youth are to truly learn about the requirements of the world of work and the consequences of not meeting such requirements, it is in their long-term interest to learn these lessons at an early age rather than later in their working lives when they have more responsibilities and obligations. By the same token, participants who perform well both on the job and in an educational setting should be tangibly and visibly rewarded. The section of this TEGL on "Integration of Work and Learning" also has important implications for the work experience component. Briefly stated, documented learning experiences should be an integral part of the youth's work experience. Objective Assessment and Individual Services Strategy (ISS): a. Legislative and Regulatory Requirements. The performance of an objective assessment for each participant and the development and implementation of an ISS are required for the CY94 summer program. ETA's expectations are that: (1) Each participant shall undergo a professional assessment of her/his functional educational levels, work maturity skills, and supportive service needs. To the extent feasible and appropriate, a participant's personal development and follow-up service needs should also be assessed; and, (2) Based on this assessment, an ISS shall be devised for each participant to address any needs or deficiencies identified, particularly basic educational skills, work maturity skills, and supportive services; and, (3) The services shall in fact be provided--or records maintained as to why each participant's needs could not be addressed. The recently enacted Goals 2000: The Educate America Act--which was effective on March 31, 1994--includes an amendment to SYETP. [When reproducible copies of the law are available, they will be sent to States. In the interim, the full text of the SYETP amendment can be found in the Congressional Record of March 21, 1994 on page H1662.] The subsection of the amendment which is relevant for this discussion states: "(a) PROGRAM DESIGN. -- "(2) REQUIRED SERVICES AND DESIGN. --(A) Subsection of (c) of such section 253 of the Job Training Partnership Act (20 U.S.C. 1632(c)) is amended by adding at the end the following new paragraphs: "'(3) BASIC EDUCATION AND PREEMPLOYMENT TRAINING. --The programs under this part shall provide, either directly or through arrangements with other programs, each of the following services to a participant where the assessment and service strategy indicate such services are appropriate: "'(A) Basic and Remedial Education. "'(B) Preemployment and Work Maturity Skills Training.'" Hence, the requirement for providing the latter two services to participants in need of them is now explicitly articulated in the law. b. Nature of the Assessment. In accordance with Section 253(2)(1)(B) of JTPA, SDAs are not required to conduct an entirely new assessment if, in the SDA's judgement, an assessment--or parts of an assessment--available from another source (e.g., local school system, the JOBS program) is appropriate. In cases of multi-year enrollments of participants, the SDA can build upon the prior year's assessment rather than starting completely anew. We recognize that, in consideration of their ages, assessments of summer youth and the ensuing ISS' need not be as elaborate as for participants in other JTPA Titles, at least in terms of long-term training. Clearly, though, the age differential among summer youth should be taken into consideration when planning/conducting assessments and devising the ISS. c. Assessment Instruments. ETA will neither require nor recommend any particular assessment device. It is the responsibility of the SDAs to utilize effective assessment instruments. Likewise, while pre- and post-testing of educational attainment is strongly encouraged (but not required), ETA will not recommend any particular testing protocol. SDAs are urged to consult with their local school systems to determine which measurements of educational achievement are most appropriate and useful to both the individual SDAs and the local school system(s). ETA recommends that SDAs specifically explore the use of participant portfolios as a measurement device. There is evidence to suggest that the use of portfolios is gaining increasing acceptance among school systems, particularly in school-to-work activities. States and SDAs are also referred to the Technical Assistance Guide on assessment distributed by ETA in connection with the JTPA Amendments of 1992. d. Timing and Funding of the Objective Assessment and ISS. There have been questions raised regarding the timing and source of funding for objective assessments and the ISS. Clearly, it would be detrimental to sound program operations to defer the performance of these activities until program operations are ready to begin. The objective assessment process and the development of the ISS can begin as soon as eligibility is determined. The sources of funding for these activities can be (singly or in combination) either CY93 carry-over funds or CY94 funds. Integration of Work and Learning: There are two inter-related principles associated with the integration of work and learning (variously referred to as "work-based learning," "contextual learning," and "functional learning"): a. Learning SCANS Foundation Skills and Competencies (or reasonable variations of SCANS) within the context of performing work on an actual job; b. Conveying work-oriented skills--particularly, but not limited to, SCANS Foundation Skills and Competencies--in a classroom setting. The March 31, 1994 amendment to SYETP codifies into law the priority DOL accords the integration of work and learning. To wit, "(a) PROGRAM DESIGN. -- "(2) REQUIRED SERVICES AND DESIGN. -- (A) Subsection (c) of such section 253 of the Job Training Partnership Act (20 U.S.C. 1632(c) is amended by adding at the end the following new paragraphs: "'(4) INTEGRATION OF WORK AND LEARNING. -- "'(A) WORK EXPERIENCE.-- Work experience provided under this part, to the extent feasible, shall include contextual learning opportunities which integrate the development of general competencies with the development of academic skills. "'(B) CLASSROOM TRAINING. -- Classroom training provided under this part shall, to the extent feasible, include opportunities which to apply knowledge and skills relating to academic subjects to the world of work.'" As the statute implies, work-based learning and classroom- based learning must complement and reinforce each other. Most SDAs' program designs have traditionally consisted of two distinct components--work experience and classroom education--with varying degrees of interaction between the two. This design continues to be acceptable, provided the two components, as indicated above, are complementary and mutually-reinforcing. Some SDAs have integrated work and learning to the point that all learning is acquired on the job. This, too, is an acceptable model, although program experience suggests that this approach is most useful for older youth who do not suffer from serious educational deficiencies. An important requirement of both models--but particularly the "all learning on the job" model--is that the participants' acquisition of SCANS skills and competencies (or reasonable facsimiles) must be documented. The use of portfolios is recommended as a documentation device. It is highly desirable for youth to actively participate in the documentation process--e.g., keeping journals which become part of the portfolios. What ETA is strongly promoting is an approach to the summer program which goes beyond static and self-contained work experience and education components; what we are seeking is a concept of the summer program as a "total learning experience," with relevant learning taking place in any activity in which a youth participates. Thus, classrooms should be transformed into interactive, work-related environments; and worksites, as indicated above, should be re-oriented to include rich learning experiences related to the SCANS foundations and competencies. The integration of work and learning is an important feature of the Administration's larger workforce agenda, particularly one of the Department of Education's and the Department of Labor's major initiatives--School-to-Work Transition (STW). The summer program can reinforce the same message being communicated to youth by STW, namely, that school and work cannot be separated; that lifelong learning matters; and that youth can avail themselves of opportunities to equip themselves for success in the labor market, without necessarily attaining a baccalaureate degree. Terms such as "classroom learning" and "classroom setting" have been used above because of their easily recognized general meanings. However, we do not in any way intend to convey the notion that we are speaking only of a traditional classroom approach. (Indeed, as Westat found, the less traditional the setting and method of instruction, the more receptive the youth were to learning.) Other, non-traditional methods of teaching and learning are also acceptable. Examples include (but are not limited to): tutoring, coaching, self-study, computer-assisted instruction, peer-to-peer teaching, collaborative learning. The important point is that there must be learning objectives articulated and documentation of progress maintained. Working Relationships Between SDAs and Local School Systems: The vast majority of SDAs rely heavily on local school systems for the delivery of educational services. Therefore, effective working relationships between the two are crucial to achieving the goals of enriching the quality of the education component and preserving educational gains made during the summer by providing services to youth year-round. The importance of effective linkages is emphasized in the March 31, 1994 amendment to SYETP: "(B) Section 253 of the Job Training Partnership Act (20 U.S.C. 1632) is further amended by adding at the end the following new subsection: "'(e) EDUCATIONAL LINKAGES. -- In conducting the program assisted under this part, service delivery areas shall establish linkages with the appropriate educational agencies responsible for service to participants. Such linkages shall include arrangements to ensure that there is a regular exchange of information relating to the progress, problems, and needs of participants, including the results of assessments of the skill levels of participants.'" Unfortunately, as Westat found and Regional Office observations confirmed, while there is frequent communication between SDAs and local school systems during the recruitment phase, communications rapidly fade as the program becomes operational and, in most instances, is virtually non-existent at the conclusion of the program and the advent of the school year. It appears that information about participants' progress and needs is not exchanged very often either prior to the youth entering the program or at the conclusion of the program. The exchange of information can be an important factor in motivating youth to perform well both during the summer program and when they return to school. For example, if progress in mastering educational skills and improving attitudes and behavior patterns during the summer program is not operationally recognized by the school system, it will justifiably raise or reinforce serious doubts in many youth's minds as to whether good efforts and achievements count for anything. We fully recognize that cooperation and communications are a two-way street. We are working with our colleagues at the Department of Education to develop ways in which they can be of assistance in promoting effective relationships between local school systems and SDAs. Generally speaking, States are in a good position to promote communication and cooperation between the two entities and are urged to do so. Individual Development: Many SYETP participants need assistance in developing and refining attitudes, values, and behavior patterns and in changing dysfunctional personal traits and conduct. It is allowable and desirable for SDAs to provide such assistance. [Many SDAs term such individual developmental activities "Life Skills" training.] Assistance should be focused on those attitudes, values, and behavior patterns which are vital to success in educational pursuits, on the job, and as a citizen. Many of the SCANS Foundation Skills (e.g., "Personal Qualities") and Competencies (e.g., "Interpersonal") are geared to individual development. Thus, SDAs are encouraged to incorporate individual development activities into learning on the job and in an educational setting. When individual development activities are integrated with learning on the job and in an educational setting, they may be properly considered part of an SDA's education component. However, stand-alone personal development activities, while allowable, are not to be considered part of the education component. [Also see below under "Reporting."] "Academic Enrichment.": Last summer, considerable confusion surrounded the meaning of the term "academic enrichment" primarily because of its newness and the policy options which were floated (but never finalized) regarding percentage requirements for funds expended on academic enrichment and the number of hours which a participant should spend in academic enrichment. Aside from numerous inquiries regarding the charging of academic enrichment costs, the most frequently asked question was how academic enrichment differed, if at all, from basic and remedial education. The reader will note that this is the first time the term "academic enrichment" appears in this TEGL; rather, the more familiar term "education" is used. This is an attempt to clear up any remaining confusion regarding academic enrichment. First, the term was adopted by Secretaries Reich and Riley to convey their firmly felt belief that the education component of the summer program had to be expanded and improved--that is to say, "enriched." Second, the term is broad in its coverage, ranging from basic and remedial education with its emphasis on the "3-R's" to instruction in other legitimate academic subjects--e.g., science, history. This summer, the term has been broadened to explicitly include learning on the job. The types of educational services provided will depend on the needs of the participants as determined by the objective assessment. This is a State and local decision. However, if a large segment of the participant population is in need of basic and remedial education, the provision of services to meet these needs should take precedence over other legitimate educational pursuits, such as advanced placement courses. In sum, "academic enrichment" has become part of the JTPA lexicon; indeed, it has become part of the law. The March 31, 1994 amendment to SYETP inserts "academic enrichment" after "remedial education" in section 253(a)(1) of JTPA. Thus, it will undoubtedly continue to be used by various sources in various contexts. When any discussion of academic enrichment is taking place, the broadness of the meaning of term should be kept in mind. Other Questions Related to the Provision of Educational Services: a. Program Design: A number of States and SDAs have asked whether it is permissible to offer educational services only to all its participants or to a defined segment, usually 14- and 15-year olds. ETA strongly prefers that all participants, including 14- and 15-year olds, spend considerable time on an actual job. Nevertheless, education- only program designs are allowable, provided that SDAs offer explanations in their job training plans as to why such a design is the most effective strategy for the youth involved. Even if such a design is approved by the State, to be consistent with the legislative purposes of SYETP, such participants must receive some form of exposure to the world of work. This may take the form of vocational exploration, job shadowing, simulated workplaces, and other such techniques. These activities should be of sufficient intensity and duration to ensure that all participants develop or refine a realistic knowledge and appreciation of the demands of the work world. The relationship between work and education must also be stressed. Obversely, other States and SDAs, following our goal of providing services to youth year-round, have indicated that they provide extra educational assistance to summer participants during the regular school year and thus provide minimal or no educational services during the summer. This is an acceptable practice, provided that: (1) SDAs maintain records on the extra educational assistance provided during the regular school year; and (2) youth gain an appreciation of the powerful connection between work and education during the regular school year and, most definitely, while working at their summer jobs; and, (3) steps are taken to ensure that an appreciable erosion of basic educational skills does not occur during the vacation period. b. Costs and Enrollments. Some elected officials, Private Industry Council members, and State and local program administrators have expressed concern that the emphasis on an expanded and enriched education component will drive up the cost per participant and thus reduce the number of youth who can be enrolled. On the face of it, this appears to be true. However, given the wide range of resources devoted to the education component by the SDAs, national data have not shown an appreciable increase in cost per participant. Nevertheless, DOL has factored increased costs for the education component in the budgets for the CY94 summer program and beyond. Therefore, we anticipate that any reductions in enrollment will be marginal. Moreover, even if reductions in enrollments occur, DOL believes that, in both the short-term and in the long run, greater investments in enriched summer programs will yield higher dividends for more youth and for society at large than is presently the case. Year-Round Services to Youth: Strengthening linkages with JTPA Title II-C was a DOL goal for last summer and is repeated as a goal for this summer's program. The March 31, 1994 amendment to SYETP facilitates the strengthening of these linkages by raising the percentage of funds which may be transferred--subject to the Governor's approval--from Title II-B to II-C from 10 percent to 20 percent. Hence, States and SDAs now have much more flexibility in linking the two programs. Limited Private Sector Internships/Entry Employment Experience: 1994 marks the first year that these activities are authorized for the summer program. Inasmuch as there are only subtle differences between the two activities and the legislative history offers no insight as to whether the Congress envisioned any major differences between the two, they will be treated singly. It is clear that certain vulnerabilities are inherent in this activity. Some examples include: a. the occurrence or perception of favoritism shown to one employer over another; b. placing economically disadvantaged youth in subsidized jobs that they can obtain on their own; c. displacing non-economically disadvantaged youth from jobs they normally secure in the summer. As a matter of sound public policy and to assist SDAs in avoiding these vulnerabilities, the selection of private employers to participate in this activity shall be based on an objective analysis of the relative "value-added" contributions to the youth's development the employer is willing to make. Illustrative, but not all-inclusive, examples of such contributions include: a. structured development/refinement of work maturity skills; b. integration of work and learning; c. provision of educational services; d. exposure to skill training; e. mentoring; f. vocational exploration/career guidance; g. commitment to hire the youth in a part-time or full-time job- -compatible with the youth's occupational interest--upon successful completion of the internship, substantial progress in or graduation from high school, or both. SDAs should maintain explanations of why a particular employer was selected or not selected to serve as a worksite. States and SDAs are cautioned to operate their internship program in tandem with their voluntary private sector summer jobs campaign [see below] so that the two initiatives complement rather than compete against each other. Payments to Participants: Allowable types of payments to participants are generally addressed in 20 CFR 627.305 of the JTPA Interim Final Regulations. Payments to SYETP participants may consist of: a. wages for participants in work activities--work experience, OJT, and limited private sector internships/entered employment experience; b. payments for participants in combined work and classroom activities; c. bonuses and/or incentives; d. supportive service payments, including financial assistance; e. needs-based payments. SYETP participants who are engaged in work activities in which there is an employer-employee relationship shall be paid wages which comply with all applicable Federal, State, and local laws governing wage payments. When participants are paid wages, they will be subject to normal withholding of taxes applicable to similarly situated employees. However, States and SDAs are reminded that the Act, at Section 143(a)(5), stipulates that funds may not be used "for contributions on behalf of any participant to retirement systems or plans." For the time spent in classroom education activities, participants may be: a. Paid wages at the same level as wages for work experience and subject to the same rules governing the payment of wages; or, b. Provided with wage equivalent payments equal to wages for work--or less; or, c. Provided with incentive or bonus payments only--or in addition to--payments specified in a. and b. immediately above; or, d. Not paid anything. The Internal Revenue Service (IRS) is solely responsible for determining whether any given compensation is subject to Social Security taxes (FICA). IRS has not issued any definitive blanket guidance about whether work experience wages are covered or exempt from FICA and it is unlikely that they will do so. IRS prefers to respond to individual fact situations. Hence, States and/or SDAs should consult directly with IRS when they have specific questions of coverage. With regard to incentive and bonus payments, a number of States and SDAs have noted that the Interim Final Regulations mention only Title II-C as a program in which participants may be provided incentive and bonus payments. Also, the Preamble to the Interim Final Rules appear to indicate that such payments are limited to Title II-C. However, the Act and regulations are silent as to whether such payments may be made to SYETP participants--that is, there is no express prohibition against them. ETA believes that incentive and bonus payments--at the SDA's discretion and subject to State policy--are appropriate under Title II-B and thus finds such that such payments are allowable provided they are based on attendance and performance. The final regulations--expected to be issued prior to the advent of summer program operations--will include a provision for the express allowability of payment of bonuses and incentives under Title II-B. Reporting: a. A Training and Employment Information Notice has been drafted by ETA which will transmit the revised JTPA Summer Performance Report. It will be issued shortly. Several changes have been made in the reporting items. This TEGL will deal with only two: (1) "Total Participants in Educational Activities." The reporting instructions will indicate that a participant is considered to have been enrolled in an educational activity if: (a) she/he participated in a structured learning experience off the job where SCANS Foundation Skills and Competencies (or reasonable variations thereof) and/or other academic disciplines are taught and progress can be measured and documented; or, (b) she/he participated in a structured learning experience on the job (e.g., "contextual learning") where SCANS Foundation Skills and Competencies (or reasonable variations thereof) and/or other academic disciplines are taught and progress can be measured and documented; or, (c) she/he participated in a structured learning experience as described above which combined learning both off the job and on the job. An explanatory note will be included which, in line with what was previously stated in this TEGL, will indicate that enrollment in stand-alone personal development courses, seminars, etc., while allowable activities, are not to be considered "educational activities." However, if the development of personal skills is an integral part of educational activities as defined above, enrollment in this activity will be considered a legitimate part of the larger educational activities rubric.] (2) "Total Participants in Private Sector Entry Employment Experience Activities." (This item includes enrollments in limited private sector internships as well as enrollments in entry employment experience. It does not include placements made as a result of the voluntary private sector summer jobs campaign. See below for a description of the campaign.) b. As part of their oversight responsibilities, States are requested to provide estimates of cumulative enrollment (only) to their Regional Offices during mid-summer and at the conclusion of the program. The mid-summer information should be compiled as of July 15, 1994 and shared with the Regional Offices on July 22, 1994. The end of program information should include cumulative enrollments through the end of the program and shared with the Regional Offices on September 23, 1994. c. All financial information is to be reported on the JQSR. Total funds carried into the Calendar Year 1994 summer program (and funds transferred to Title II-C) from the Calendar Year 1993 program are to be reported on a Program Year (PY) 1992 JQSR. Instructions for reporting these items are found in TEIN No. 6-93, Change 1, issued January 13, 1994. PY93 funds allotted for the Calendar Year 1994 summer program will be reported as available on the fourth quarter Program Year 1993 JQSR. All transfer and expenditures data related to this allotment will also be reported on the JQSR. Instructions for completion of the JQSR are contained in TEIN 6-93, issued July 30, 1993. d. States and SDAs are strongly urged to devote intensified attention to accurate and timely reporting. This issue is of serious concern to ETA. For the past few summers--but especially last summer--both enrollment and expenditure data reported to ETA underwent numerous revisions. Such "moving targets" pose major difficulties for DOL's budgeting process. Even more importantly, they pose Congressional and public information problems, not just for DOL, but for the JTPA system as well. States are urged to develop or refine administrative policies and procedures (e.g., reallocation within the State) which will promote maximum utilization of funds. Job Safety and Health: States and SDAs are referred to: a. Section 143(a)(2) of JTPA: "Health and safety standards established under State and Federal law, otherwise applicable to working conditions of employees, shall be equally applicable to working conditions of participants." [This coverage applies to age restrictions on the type of job activities which a participant may perform.]; b. TEIN No. 33-92: "Child Labor Restrictions Applicable to Youth Participants in Job Training Partnership (JTPA) Funded Programs." States and SDAs are strongly encouraged to re-familiarize themselves with Federal, State, and local job safety and job health standards and child labor restrictions to ensure that participants are not assigned to job activities which violate the standards and/or restrictions. Voluntary Private Sector Summer Jobs Campaign: President Clinton and Secretary Reich are strong proponents of organized and energetic efforts to secure private sector summer jobs for needy youth. A number of SDAs have demonstrated that such campaigns can be highly successful. A separate TEIN will be issued shortly which will outline DOL's national efforts in this regard. While DOL will promote and support the campaign nationally--and States can and should play a vital promotion and support role as well--the success of any such campaign is mainly attributable to solid local level partnerships between government and business leaders. Technical assistance, which will be specified in the upcoming TEIN, will be made available to a limited number of SDAs who demonstrate a need and commitment to mount an effective campaign. Improving Public Knowledge of the Program: Many SDAs administer or operate exciting work projects in which the youth provide valuable services to their communities and to the public at large. Yet, as Westat has found, such efforts often go unnoticed. Nor does it appear that the public realizes the valuable services provided to the youth--e.g., work maturity skills, educational gains, more functional attitudes and behavior patterns. Similar to the voluntary private sector summer jobs campaign, DOL will promote public awareness of the benefits of the summer program at the national level. States are encouraged to do the same. However, the effectiveness of any such efforts rests squarely with the SDAs. One of the technical assistance guides developed by Brandeis University (see below under "Technical Assistance and Training) includes helpful advice on disseminating information on the summer program to schools, employers, and the public. DOL has some additional ideas to improve the visibility of the summer program and can offer technical assistance to self-selected SDAs. Regional Offices have already been working with States to identify such SDAs. DOL will issue additional materials in the near future. In the interim, States and SDAs should seriously re-examine their public and community relations efforts. National Development of Worksites: As it did last summer, ETA has been working with the U.S. Office of Personnel Management to facilitate the placement of youth in Federal agencies. We are also working with the U.S. Forest Service and the National Forest Foundation to develop both residential and non-residential worksites. States are also referred to TEIN No. 40-93 which provided information on the current activities of the National Civilian Community Corps and requested cooperation from States and SDAs in the implementation of NCCC's activities. These activities may be of value to summer program participants. Technical Assistance and Training: The availability of training on techniques to enrich the summer program was announced in TEIN No. 39-73. ETA will shortly issue technical assistance guides (TAGs) on various aspects of the summer program. These TAGs have been prepared by Brandeis University and KRA Associates, who are conducting the training. We are now printing worksite supervisor handbooks--developed by Brandeis and Johns Hopkins University--which feature techniques to incorporate SCANS foundations and competencies on the job. Handbooks for the five most common summer program occupations have been prepared. As mentioned earlier, the previously issued Technical Assistance Guide on assessment may also prove helpful. Both Brandeis University and P/PV are available to assist States and SDAs in the design and operation of local adaptations of the program models the two organizations have developed--Summer Beginnings (Brandeis), STEP, PECE, and Summer Internships (P/PV). Brandeis and P/PV are also available to deliver assistance on enriching a summer program in general. However, financial arrangements for such assistance must be made between States and/or SDAs and Brandeis and P/PV. Regional Offices will be working with the States to design and deliver peer-to-peer TAT on an enriched education component. Technical assistance for the voluntary private sector summer jobs campaign and public and community awareness initiatives were discussed earlier. Oversight: Regional Office oversight will be primarily targeted to those States and SDAs which have: a. significantly underperformed in CY93 with regard to expenditures and enrollments; b. historically provided only little (or no) educational services and/or the quality of the education component has been poor. Regional Offices and States will also be reviewing the implementation of program requirements, such as objective assessment and the ISS, integration of work and learning, relationships with local school systems, private sector internships/entry employment experience, etc. A national oversight strategy has been developed which allows for a great deal of flexibility among Regional Offices. Each Regional Office will be working with the States in their region to jointly develop a coordinated oversight plan. The front line of oversight is of course occupied by the SDAs themselves. It is expected that vigilant SDA monitoring of program operations will continue. Evaluation: Evaluation efforts for this summer will focus on: a. Assessing the differential effects of participation in various summer program designs--mainly related to how educational services are delivered--on subsequent performance in school; b. Ascertaining the effects of receiving services year-round; c. Conducting a process analysis of the implementation of the limited private sector internship/entry employment experience activities. Additional information on the evaluation design will be provided at a later date. As they have in the past, States and SDAs are expected to cooperate with the evaluation effort. Overall ETA Expectations: ETA is aware that the program improvements it has specified in this TEGL represent major innovations for many SDAs. We also aware that this program guidance and the amendments to SYETP appear while most SDAs are in the midst of planning their summer programs. We recognize that all the enhancements and enrichments will not be fully implemented across all SDAs in one summer. In examining and analyzing SDAs' progress, we will take cognizance of the diversity of SDAs in terms of the degree of enhancements and enrichments that they have implemented in the past. However, we do expect significant progress to made by all SDAs in initiating and refining the program requirements and improvements discussed in this TEGL. Dissemination of Program Guidance: States should transmit this guidance to SDAs as expeditiously as possible. In addition, States should instruct SDAs to quickly provide relevant guidance to worksites and service providers.

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References: Wagner-Peyser Act, as amended (29 U.S.C. 49); 20 CFR 652 and 20 CFR 653; JTPA Sections 202, 252, 262, 302, and 601, as amended by the Job Training Reform Amendments Act of 1992; Training and Employment Guidance Letter (TEGL) No. 4-88. Background: The JTPA Titles II-A, II-C and III allotments, and the Wagner- Peyser preliminary planning estimates, are for the program period July 1, 1995, through June 30, 1996. The Title II-B allotments are for the CY 1995 summer program. These JTPA allotments and the Wagner-Peyser preliminary planning estimates will be pub-lished in the Federal Register. The allotments for Titles II-A, II-C, and III, and the ES preliminary planning estimates are part of the Fiscal Year 1995 funds appropriated in the Department of Labor Appropriations Act, 1995, P.L. 103-333, for PY 1995. These appropriations include $1,054,813,000 for Title II-A, a 6.76 percent increase from the PY 1994 Title II-A level; $598,682,000 for Title II-C, a 1.64 percent reduction from the revised PY 1994 Title II-C level (including the $50 million rescission); $1,296,000,000 for Title III, a 15.92 percent increase from PY 1994; and $845,912,000 for allotments to States under Wagner-Peyser, a 1.57 percent increase from PY 1994. The base allotments for Title II-B total $867,070,000, or 1.09 percent below the previous year's level. Included in these allotments are funds from the Fiscal Year (FY) 1995 appropriation in the amount of $184,788,000. The 1994 and 1995 funds available for the CY 1995 Title II-B program will be issued through separate Notices of Obligation (NOOs). The $184,788,000 will not be available until July 1, 1995, at which time NOOs will be issued. The remainder will be issued on April 1, 1995. An additional $3,861,000 has been appropriated for Title II activities in rural concentrated employment program (RCEP) areas, the same as the previous year's level. Distribution of funds for the RCEPs is discussed below under item 5. JTPA/ES Joint Planning and Coordination Provisions: As plans are developed in accordance with relevant statutory provisions and schedules issued by the Department, States are reminded that particular attention needs to be given to the Governor's statement of goals and objectives for JTPA, and joint ES/JTPA planning initiatives consistent with Section 8(b) of the Wagner-Peyser Act, as amended. Note that further planning guidance may be provided for specific programs at a later date. RCEP States: Additional funds are available to assure, to the maximum extent possible, that funding for RCEPs under Title II programs is maintained at prior year levels. The Department previously reserved $250,000 from PY 1994 RCEP funds to be used for this purpose in the CY 1995 summer program. The RCEP appropriation for PY 1995 is $3,861,000. Of this amount, $250,000 is being reserved for the CY 1996 summer program. Therefore, $3,611,000 will be available for PY 1995 Titles II-A and II-C programs. It will be necessary for the States of Kentucky, Minnesota, Montana, and Wisconsin to provide the Department with the amount of the Titles II-A, II-B, and II-C RCEP allocations based on the allotments contained in this TEGL. This information should be sent no later than February 16, 1995, to the following address: Donald J. Kulick Deputy Administrator Office of Job Training Programs 200 Constitution Avenue, N.W. Room N-4459 Washington, D.C. 20210 Notice of Obligation (NOO): NOOs for the CY 1995 Title II-B summer youth program funds included in the FY 1994 appropriation, as well as the additional funds for RCEPs, will be issued in April. The NOOs for the remaining $184,788,000 appropriated in FY 1995 for the Title II-B program will be issued on July 1, 1995, because Congress appropriated these funds to be effective on that date. NOOs for the PY 1995 Title II-A, II-C, and III programs will be issued on July 1, 1995 and will include the additional Title II-A and II-C funds for the RCEPs. A second NOO will be issued to each State after November 1, 1995, for Title III, to increase or reduce the funds available to the State to reflect the amount of reallotted funds the State gains or loses, as discussed in TEGL No. 4-88. Title II-A Allotments: Attachment I shows the PY 1995 JTPA Title II-A allotments by State. For all States, Puerto Rico and the District of Columbia, the following data were used in computing the allotments: - Data for Areas of Substantial Unemployment (ASUs) are averages for the 12-month period, July 1993 through June 1994. - The number of excess unemployed individuals or the ASU excess (depending on which is higher) are averages for this same 12-month period. - The economically disadvantaged adult data (age 22 to 72, excluding college students and military) are from the 1990 Census. The allotments for the Insular Areas are based on unemployment data from the 1990 census, or if not available, the most recent data available. A 90-percent relative share "hold-harmless" of the Title II-A PY 1994 allotments for these areas and a minimum allotment of $75,000 were also applied in determining the allotments. Title II-A funds are to be distributed among designated SDAs according to the statutory formula contained in Section 202(b) of JTPA, as amended by Title VII, Miscellaneous Provisions, of the Job Training Reform Amendments of 1992. (This Title VII provides an interim allocation methodology which applies to the PY 1995 allotments). This is the same formula that has been used in previous program years; however, prior to PY 1993 a different definition of "economically disadvantaged" was used. In determining any necessary hold-harmless levels for SDAs, the States of Kentucky, Minnesota, Montana, and Wisconsin shall not include any additional funds provided for RCEPs. Title II-B Allotments: Attachment II shows the 1995 JTPA Title II-B allotments by State and by fund source, with totals. The data used for these allotments are the same data as were used for Title II-A allotments, except that data for the number of economically disadvantaged youth (age 16 to 21, excluding college students and military) from the 1990 census was used. For the Insular Areas and Native Americans, the allotments are based on the percentage of Title II-B funds each received during the previous summer. Title II-B funds for the 1995 Summer program are to be distributed among designated SDAs in accordance with the statutory formula contained in Section 252(b) of JTPA, as amended by Title VII, Miscellaneous Provisions, of the Job Training Reform Amendments of 1992. (This Title VII provides an interim allocation methodology which applies to the PY 1995 allotments). This is the same formula that was used in the previous program year. In determining any necessary hold-harmless levels for SDAs, the States of Kentucky, Minnesota, Montana, and Wisconsin shall not include any additional funds provided for RCEPs. Title II-C Allotments: Attachment III shows the 1995 JTPA Title II-C allotments by State. The data used for these allotments are the same data as were used for Title II-B allotments. The allotments for the Insular Areas are based on unemployment data from the 1990 census or, if not available, the most recent data available. A 90-percent relative share "hold-harmless" of the PY 1994 Title II-C allotments for these areas and a minimum allotment of $50,000 were also applied in determining the allotments. Title II-C funds are to be distributed among designated SDAs according to the statutory formula contained in Section 262(b) of JTPA, as amended by Title VII, Miscellaneous Provisions, of the Job Training Reform Amendments of 1992. (The Title II-C formula is the same as for Title II-B). This is the same formula which has been used in the previous program year. In determining any necessary hold-harmless levels for SDAs, the States of Kentucky, Minnesota, Montana, and Wisconsin shall not include any additional funds provided for RCEPs. Title III Allotments: Attachment IV shows the PY 1995 JTPA Title III allotments by State. The total appropriation includes 80 percent allotted by formula to the States, while 20 percent is retained for the National Reserve account, including funds allotted to the Insular Areas. Title III formula funds are to be distributed to State and substate grantees in accordance with the provisions in Section 302(c) and (d) of JTPA, as amended. The unemployment data used for computing these State allotments, relative numbers of unemployed and relative numbers of excess unemployed, are averages for the October 1993 through September 1994 period. Long-term unemployed data used were for CY 1993. Allotments for the Insular Areas are based on the PY 1995 Title II- A allotments for these areas. Reallotments: Reallotments of these Title III formula funds, as provided for by Section 303 of JTPA, as amended, will be based on completed program year expenditure reports submitted by the States and received by October 1, 1995. Title III allotments will be adjusted upward or downward, based on whether the State is eligible to share in reallotted funds or is subject to recapture of funds. ES Planning Estimates: Attachment V shows ES planning estimates for PY 1995, which have been produced using the formula set forth at Section 6 of the Wagner-Peyser Act, 29 U.S.C. 49e. These preliminary estimates are based on averages for the most current 12 months ending September 1994 for each State's share of the civilian labor force (CLF) and unemployment. Final planning estimates will be published in the Federal Register, based on Calendar Year 1994 data, as required by the Wagner-Peyser Act. The total planning estimate does include $22,019,700 or 2.603 percent of the total amount available which is being withheld from distribution to States to finance postage costs associated with the conduct of Employment Service business for PY 1995. The Secretary of Labor has set aside 3 percent of the total available funds to assure that each State will have sufficient resources to maintain statewide employment services, as required under Section 6(b)(4) of the Wagner-Peyser Act. In accordance with this provision, $24,716,769 is set aside for the administrative formula allocation. These setaside funds are included in the total planning estimate. Set-aside funds are distributed in two steps to States which have lost in relative share of resources from the prior year. In step one, States which have a CLF below one million and are below the median CLF density are maintained at 100 percent of their relative share of prior year resources. All remaining set-aside funds are distributed on a pro rata basis in step two to all other States losing in relative share from the prior year but which do not meet the size and density criteria for step one. Ten percent of the total sums allotted to each State shall be reserved for use by the Governor to provide performance incentives for public ES offices; services for groups with special needs; and for the extra costs of exemplary models for delivering job services. Action: a. States should allocate the JTPA allotments as follows: (1) Title II-A allotments according to the requirements contained in Sections 162(e) and 202(b) of JTPA, as amended, subject to Title VII of the JTPA Amendments. (2) Title II-B allotments according to the requirements contained in Sections 162(e), and 252(b) of JTPA, as amended, subject to Title VII of the JTPA Amendments. (3) Title II-C allotments according to the requirements contained in Sections 162(e) and 262(b) of JTPA, as amended, subject to Title VII of the JTPA Amendments. (4) Title III allotments according to the requirements contained in Sections 302(c) and (d) of JTPA, as amended. b. RCEP States should forward the following information to the address listed in item 5 above not later than February 16, 1995: (1) PY 1995 Titles II-A and II-C formula allocations for the RCEPs in Kentucky, Minnesota, Montana, and Wisconsin. (2) CY 1995 Title II-B formula allocations for RCEPs in these States. c. States should initiate planning for PY 1995 ES programs consistent with provisions of the Wagner-Peyser Act and Federal Regulations at 20 CFR Part 652.

Reference: TEIN 18-88 and Attachment. Background: Effective October 1, 1993, financial information for JTPA Title II-B grants is now reported on the JTPA Quarterly Status Report (JQSR) with similar data for Title II-A/C. A Statewide JASPR format has been developed to capture non- financial information for Title II-B activity on an annual basis. NOTE: This report replaces the former JTPA Summer Performance Report (ETA 9010). Also, the JASPR will be used to report separately such annual information for the JTPA Title I, Section 123, State Education Coordination (8%) grant. Office of Management and Budget (OMB) Approval and Reporting Burden: The JASPR reporting requirements are pending approval by OMB in accordance with the Paperwork Reduction Act of 1980, as amended. Upon receipt of final OMB approval, States will be notified to implement this report and will be provided with the OMB approval number and expiration date. Reporting Instructions: Governors will submit separate annual JASPRs for the Title II-B grant and for the Title I, Section 123, grant, as specified in the instructions for preparation of the JASPR. The JASPR initially will be used to capture these required data for the report periods ending September 1994 for Title II-B and June 1994 for Title I, Section 123, grants. Action Required: State Liaisons are requested to distribute the attached instructions to all officials within the State who need such information to implement the JASPR reporting requirements.

References: ET Handbook 392; ET Handbook 399; Interstate Benefit Payment Plan. Background: Over the past few years, major changes to the procedures for handling the claims of interstate and combined wage claimants have occurred. Changes to both the interstate and intrastate claimstaking methods limit contact with claimants and opportunities for the exchange of information and questions to be answered. These evolving changes increase the need for information pertaining to claimant's rights and responsibilities to be in different and accessible mediums. Under an agreement with the Department of Labor, and in consultation with the Interstate Conference of Employment Security Agencies' Interstate Benefit Committee, the State of Washington has developed and produced an interstate BRRI video and booklet for national distribution. All States were contacted to provide information for consideration during the development of the material. The video has been produced in English, open captioned, and in three Spanish dialects. The informational booklet has been produced in English and Spanish (academic). All States that requested customized versions of the video, to include their specific agent State information, were accommodated. Distribution of Materials: Distribution of the videos and a camera ready copy of the English and Spanish versions of the informational booklets is scheduled for the second and third week of April 1994. The materials will be shipped to the attention of the UI Director for each State under separate cover. The number of copies of the video and language types that will be sent will be based on the quantity requested by each State's representative. The Employment and Training Regional Office will receive a copy of each version of the video and both booklets. Suggested Use of the Materials: It is suggested that copies of the informational booklets be distributed to all local UI offices, Job Service offices, Community Service Centers or One-Stop Service Centers, etc., where claimant contacts are made. These booklets should be included in the information provided by the agent or paying State to each individual filing an interstate or combined wage claim at the time the claim is filed. The videos should be used in providing group benefit rights information, and should also be accessible by claimants on any automated video informational system. Action Required: State Administrators are requested to make this letter available to all appropriate staff and ensure that the materials distributed are used by the State in the manner intended.

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References: The Wagner-Peyser Act, as amended (P.L. 97-300); 20 CFR 652; TEGL No. 2-93. Background: The Secretary of Labor is issuing final planning allotments for each State's share of PY 1994 funds for basic labor exchange activities. These allotments (Attachment I) are based on the FY 1994 appropriation of $832,856,000 and are distributed by the statutory formula described in Section 6 of the Act. The allotments will be published in the Federal Register. The data used are Calendar Year 1993 averages of civilian labor force (CLF) and number of unemployed individuals. Section 6(b)(4) of the Act authorizes the Secretary of Labor to reserve up to 3 percent of the total fund availability to assure that each State will have sufficient resources to maintain statewide employment service (ES) activities. The setaside for distribution through an administrative formula for this program year is $24,396,018. The 3 percent distribution is included in the total final allotment. The setaside was distributed in two steps to States whose relative share of resources declined from the previous year. In Step 1, those States with a CLF below one million and that are also below the median CLF density were held harmless at 100 percent of their prior year relative share of resources. The remainder was distributed in Step 2 in pro rata shares to all other States that lost in relative share from the prior year but did not meet the size criteria for Step 1. Differences between preliminary and final planning estimates are caused by the use of Calendar Year data as opposed to the earlier data used for preliminary planning estimates. We have attached correspondence (LAUS Technical Memorandum No. 5-94-11) from the Bureau of Labor Statistics (BLS) describing the changes. Ten percent of the total sums allotted to each State shall be reserved for use by the Governor to provide performance incentives for public ES offices; services for groups with special needs; and for the extra costs of exemplary models for delivering job services. Postage Costs: Postage costs incurred by States during the conduct of ES activities are billed directly to the Department of Labor by the U.S. Postal Service. The total planning estimate does not include $19,665,400 of the total amount available, which is withheld for the payment of the States' ES penalty mail costs. The Department had planned to require State Employment Security Agencies (SESAs) to convert from penalty mail systems to commercial mail systems effective October 1, 1994, at which time the Employment and Training Administration (ETA) had planned to allocate national postage reserves to the SESAs. Based on a legal opinion, the Department cannot require this conversion. SESAs are entitled to the penalty mail privilege pursuant to 39 U.S.C. 3202(a)(1)(E). This does not impact on the change to direct accountability that SESAs implemented on October 1, 1993. States will continue to use penalty mail systems (penalty meters, penalty stamps and envelops, permit G-12, and Business Reply Mail permit 12634) and ETA will continue to pay the SESA penalty mail costs to the U.S. Postal Service. ETA will explore with the U.S. Postal Service the possibility of having individual State penalty mail agreements with the U.S. Postal Service. This would permit ETA to allocate postage resources to the States who could then have the option of using commercial or penalty mail systems. It continues to be Departmental policy that States utilize commercial mail methods for mail which pertains to both employment security and non-employment security business. In such instances, ETA will reimburse the SESA for the employment security share of the cost. For information purposes only, Attachment II reflects Wagner-Peyser allotments including the amount reserved for postage. Action: State planning activities are to be guided by the process described in 20 CFR 652 and Training and Employment Guidance Letter No. 2-93.

Reference. Farmworker Bulletin (FWB) No. 91-30 (September 13, 1991), "Findings from the National Agricultural Workers Survey 1990." Background. FWB No. 91-30 described the origin and purpose of the National Agricultural Workers Survey (NAWS), and transmitted the first in a series of NAWS publications. Transmittal. The enclosed copy is the second in the series, although it reports on the first year of NAWS. Action Required. None. Inquiries. For additional copies and other inquiries, contact the Federal Representative assigned to your grant.