TEGL_22-19.pdf

ETA Advisory File Text

EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION SCSEP CORRESPONDENCE SYMBOL OWI DNPTTA DATE May 28 2020RESCISSIONS TEGL 17- 17 EXPIRATION DATE Continuing ADVISORY TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 22-19TO SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM GRANTEES FROM JOHN PALLASCH Assistant Secretary SUBJECT Program Year PY 2020 Planning Instructions and Allotments for Senior Community Service Employment Program SCSEP State Territory and National Grantees and Implementation of SCSEP Provisions of the Coronavirus Aid Relief and Economic Security Act CARES Act 1.Purpose. This Training and Employment Guidance Letter TEGL provides SCSEP state and territor y grantees with PY 20 20 SCSEP allotments and the applic ation instructions for PY 20 20 grant submission s. This TEGL also provides current SCSEP national grantees with allotments and application instructions for the first four months of PY 2020 the TEGL provides only partial -year funding for national grantees because PY 2020 is a competition year and these funds will cover the transition period leading up to the competition effective date. This TEGL also provides information on the transition to grants that will be awarded under the SCSEP Funding Opportunity Announcement FOA . Finally this TEGL provides implementation guidance for SCSEP provisions of the CARES Act. 2.Action Requested. To apply for PY 2020 grant funds SCSEP grantees must follow the instructions in this TEGL and submit all documents through grants.gov as soon as possible and no later than June 19 2020. 3.Summary and Background. a.Summary. This TEGL provides grant planning guidance to SCSEP grantees for PY 2020 including the number of authorize d positions and associated allotments for the program year and ETA s requirements for obligating funding to grantees . This TEGL also provides implementation guidance for SCSEP provisions of the CARES Act. 2 b. Background. SCSEP funds are allocated by a formu la set forth in Sec. 506 of the Older Americans Act OAA and SCSEP operate s on a program year basis from July 1 through June 30 of the following year. The Further Consolidated Appropriations Act of 2020 Pub. L. 116-94 from this point forward referred to as the Act Division A Section 107 allows the Secretary to reserve 0.75 percent of the appropriated funds for evaluations. Any funds not utilized for these reserve activities will be distributed by formula to state territorial and national grantees. In PY 2020 after reducing the appropriation by 4 599 000 for set asides 400 401 000 is available for SCSEP program activities. This TEGL covers the four-month national grantee transition period totaling 104 075 209. 4. Annual Grant Instructions This section provides detailed submission instructions for state and territory formula grantees as well as current national grantees. Note that in some sections this TEGL provides current national grantees with different instructions since the funds provided under this TEGL only cover the four-month transition period preceding the November 1 2020 effective date for the PY 2020 national grant competition. a. Program Allotments Attachment I All Grantees. Attachment I details the funding amounts and au thorized positions for each grantee in PY 20 20 . The allotments reflect set -asides authorized by the Act . b. Grant Application Requirements. Grantees must submit a complete grant package in order to receive PY 2020 funds. ETA will not be able to timely obligate funds to any grantee that fails to provide all of the information outlined in this guidance. Additionally grantees must ensure that the components of the grant application package are consistent with each other. i. Application and Budget Information Form All Grantees. Grantees must submit current versions of the SF-424 Application for Federal Assistance and the SF-424A Budget Information Form. Budgets must include the non- Federal share of at least 10 percent of the total cost OAA Sec. 502 c 1 . The budget must also reflect organizational information provided in the Program Narrative Organizational Structure. These interactive documents and accompanying instructions are available at the following link1 https www.grants.gov forms sf-424-family.html. ii. Geographic Areas All Grantees. Item 14 of the SF-424 requires a list of the Areas Affected by Project. Grantees must list the states and counties the grant will serve and must use www.scseped.org to validate that information. Grantees can export the data for the service area s to an Excel spreadsheet and attach the list as a separate document. iii. Budget Narrative Attachment II All Grantees. Grantees must submit a budget narrative that provides the information outlined in Attachment II including A detailed description of costs associated with each line item on the SF- 424A Budget Information Form 1 Choose the SF-424 and SF-424A that note Agency Owner as Grants.gov . 3 Both the percentage and total dollar amount allocated to participant wages and fringe benefits as described at 20 CFR 641.565 Both the percentage and total dollar amount allocated to administrative costs as described at 20 CFR 641.856 including an explanation in the budget narrative regarding whether the grantee is requesting to increase its administrative cost limitation as described below under Increase of the Administrative Cost Limitation and in Attachment V and Infrastructure contributions to the workforce system in accordance with WIOA Sec. 121 h . iv. Program Narrative. State and Territory Grantees Attachment III.a Attachment III.a requests information regarding services to minorities as well as the grantee s organizational structure and monitoring plans. If the grantee already provided all this information in the state plan they may note that in their submission which ETA will then validate missing information from the State Plan will require further submissions. Grantees may also simply copy the language from the state plan for submission here. Current National Grantees Attachment III.b Other than the Budget Narrative current national grantees are not required to submit a new program narrative for the four-month period covered by this TEGL. Rather a generic statement of work see Attachment III.b addressing the programmatic activities for four months will be incorporated into the grant agreement. v. Programmatic Assurances Attachment IV All Grantees. Grantees must review the programmatic assurances in Attachment IV that outline program requirements based on the OAA and the SCSEP regulations at 20 CFR Part 641. The signature of the Authorized Representative on the SF-424 also certifies that the organization agrees to adhere to the programmatic assurances listed in Attachment IV note that grantees are not required to separately sign and submit Attachment IV . vi. Optional Requests Attachment V . State and Territory Grantees State and territory grantees may submit one or more optional requests according to the instructions in Attachment V. As instructed in Attachment V please provide such requests in a separate clearly-titled document. Current National Grantees For current national grantees that choose to submit optional special requests for the first four months of PY 2020 the Department strongly encourages submissions that are consistent with these grantees currently approved special requests from PY 2019. This will enable current grantees to continue providing essentially the same services for an additional four months during the transition and will allow an expedited review of such requests by the Department. Note that such optional special requests made at this time must be based on funding for four months. After grant awards are made successful grantees may choose to submit optional special requests for the remainder of PY 2020 4 November 1 2020 through June 30 2021 and will receive subsequent instructions for doing so. c. Notices of Award. ETA will issue Notices of Award with new grant numbers and allocation amounts to SCSEP grantees for PY 2020 . d. Office of Management and Budget OMB Approval. As required by the Paperwork Reduction Act OMB has reviewed and approved this information collection OMB Control Number 1205-0040 which expires on November 30 202 1 . Under 5 CFR 1320.5 b an agency cannot conduct sponsor or require a response to a collection of information unless the collection displays a valid OMB Control Number. Transition Instructions for National Grantees. ETA will issue new grants to current grantees for the first four months of PY 2020 to continue services to their current authorized positions in their current areas. As noted above these new grants will be four months proportional share i.e. 33 percent of the total PY 2020 national grantee funding to serve clients during the first four months July 1 2020 through October 31 2020 . The remaining PY 2020 funds will be allocated after the announcement of the FOA results. After ETA announces the results of the FOA any current national grantees that applied under the competition and are successful will receive a modification of the new grant for the remainder of the program year November 1 2020 through June 30 2021. Current grantees that are not successful will be required as a condition of the grant award to assist in transition activities during the remainder of the first four months to ensure the least disruption for participants. Implementation of SCSEP Provisions of the CARES Act All Grantees. The CARES Act Public Law 116-136 was signed into law on March 27 2020 and responds to the COVID-19 i.e. coronavirus disease 2019 outbreak. The new law under Sec. 3223 Continuity of Service and Opportunities for Participants in Community Service Activities under Title V of the Older Americans Act of 1965 provides the Secretary of Labor the Secretary authority to allow certain administrative flexibilities to help SCSEP grantees respond to the effects of the COVID-19 public health emergency. ETA is implementing the SCSEP-related provisions of the CARES Act as follows a. Extension of Individual Durational Limits The CARES Act Sec. 3223 1 A provides the Secretary authority to allow individuals participating in SCSEP projects as of March 1 2020 to extend their participation for a period that exceeds the 48-month durational limit described in OAA Sec 518 a 3 B i if such an extension is appropriate due to the effects of the COVID-19 public health emergency. Given the widespread and ongoing impact of the emergency on SCSEP grantees and participants ETA finds that such extensions of individual durational limits are appropriate for all SCSEP grantees in all areas of the country. Accordingly this TEGL extends the individual durational limit by 12 months for all SCSEP participants who were enrolled in SCSEP as of March 1 2020 and for all SCSEP participants who enroll during the six-month enrollment period from March 1 2020 through August 31 2020. Note that this extension of individual durational limits is in addition to any other 5 extensions provided to individuals under 20 CFR 641.570 b . Grantees are not required to submit any documentation to implement this provision the change is automatically effective retroactive to March 1 2020 as described above. The change will be operationalized in the SCSEP performance and reporting system as soon as practicable and ETA will provide grantees with additional information through technical assistance. Prior to August 31 2020 ETA will reassess the status of the impact of COVID-19 if ETA determines that lengthening the six-month enrollment period described above is appropriate it will provide additional guidance to SCSEP grantees in a change to this TEGL. b. Increase of the Average Participation Cap The CARES Act Sec. 3223 1 B provides the Secretary authority to increase the average participation cap for eligible individuals applicable to grantees as described in OAA Sec. 502 b 1 C of the OAA to a cap that is appropriate due to the effects of the COVID-19 public health emergency. For the same reasons described above in Extensions of Individual Durational Limits ETA finds that such an increase on the average participation cap is appropriate for all SCSEP grantees in all areas of the country. Accordingly this TEGL increases the average participation cap for all grantees by an amount that accounts for the individual durational limit extensions described above. Grantees are not required to submit any documentation to implement this provision the change is automatically effective beginning in PY 2019 and will remain in effect as long as necessary to account for the extensions of individual durational limits described above. c. Increase of the Administrative Cost Limitation The CARES Act Sec. 3223 2 provides the Secretary authority to increase the administrative costs for a project as described in OAA Sec. 502 c 3 to an amount not to exceed 20 percent of the grant amount if such an increase is appropriate due to the effects of the COVID-19 public health emergency. Accordingly this TEGL provides SCSEP grantees the opportunity to request an increase to their administrative cost limitation to up to 20 percent of the grant amount if the grantee can demonstrate that such an increase will help it mitigate the impact of the COVID-19 public health emergency on its operations employees and or participants. As noted above in the instructions for the Budget Narrative and in Attachment II grantees should note in their Budget Narrative whether they plan to request the increased 20 percent cost limitation. To use this flexibility grantees must request and obtain ETA s approval according to the instructions in Attachment V Optional Special Requests addressing the justification requirements in 20 CFR 641.870. 5. Inquiries. Please direct inquiries to the appropriate Regional Office. 6 6. References. OAA Reauthorization Act of 2016 Pub. L. 114-144 April 19 2016 Further Consolidated Appropriations Act of 2020 Pub. L. 116-94 Decemb er 20 2019 Coronavirus Aid Relief and Economic Security Act of 2020 CARES Act Pub. L. 116-136 March 27 2020 SCSEP Final Rule 75 Federal Register FR 537864 September 1 2010 published at 20 CFR Part 641 TEGL 17-16 Infrastructure Funding of the One-Stop Delivery System January 18 2017 WIOA Pub. L. 113-128 Sec. 121 Funding of One-Stop Infrastructure Paperwork Reduction Act of 1995 Pub. L. 104-13 May 22 1995 SCSEP Performance Data Collection Approval Office of Management and Budget No. 1205-0040 expiration date November 30 2021 . OMB Uniform Administrative Requirements Cost Principles and Audit Requirements for Federal Awards Final Rule 78 FR 78589 December 26 2013 published at 2 CFR Part 200 TEGL 12-06 Revised Income Inclusions and Exclusions and Procedures for Determining Senior Community Service Employment Program SCSEP Eligibility December 28 2006 VOW Veterans Opportunity to Work to Hire Heroes Act of 2011 Pub. L. 112-56 November 21 2011 The Fair Labor Standards Act of 1938 as amended through Pub. L. 115-141 M arch 23 2018 and 2020 Federal Poverty Guidelines 85 FR 3026 January 15 2020 . The Social Security Act of 1935 as amended through Pub. L. 89-97 July 30 1965 . 7.Attachments. Attachment IA-IE Funding Allocations and Authorized Positions Attachment II Budget Narrative Instructions Attachment III.a Program Narrative Instructions for State and Territory Grantees Attachment III.b Generic Program Narrative for Current National Grantees Attachment IV Programmatic Assurances Attachment V Optional Requests Attachment IA USDOL ETA Senior Community Service Employment Program PY 2020 Authorized Positions and Funding 12 months for State Agencies and Territories by State States PositionsDollars Alabama153 1 481 418 Alaska1761 709 831 Arizona1101 063 750 Arkansas1501 455 314 California7076 858 901 Colorado83809 233 Connecticut90874 494 Delaware1761 709 831 District of Col48463 351 Florida4874 718 350 Georgia1831 775 091 Hawaii1761 709 831 Idaho44425 693 Illinois3213 112 936 Indiana2162 094 869 Iowa1061 024 594 Kansas84815 759 Kentucky1571 520 575 Louisiana1391 350 897 Maine51495 981 Maryland1141 102 906 Massachusetts1801 742 461 Michigan2752 669 164 Minnesota1961 899 087 Mississippi102991 963 Missouri2041 977 400 Montana52502 507 Nebraska63613 450 Nevada44425 693 New Hampshire44425 693 New Jersey2332 258 021 New Mexico46450 299 New York5455 286 118 North Carolina2162 094 869 North Dakota50482 929 Ohio3603 491 448 Oklahoma1331 285 636 Oregon1211 174 693 Pennsylvania4414 281 104 Puerto Rico1131 096 380 Rhode Island44430 720 South Carolina1121 089 854 South Dakota57554 716 Tennessee1681 631 518 Texas4584 437 729 Utah55535 138 Vermont46443 773 Virginia1791 735 935 Washington1221 181 219 West Virginia93900 598 Wisconsin2112 049 186 Wyoming44425 693 State Agencies Total8 778 85 138 599 American Samoa94911 027 Guam94911 027 Northern Marianas31303 677 Virgin Islands94911 027 Territories Total313 3 036 758 Based on cost per position of 9 698 with enacted minimum wage increase effective 7 24 09 State Agencies Territories Attachment IB U. S. Department of Labor Employment Training AdministrationSenior Community Service Employment Program PY 2020 Authorized Positions for Non-Minority National Sponsors by State State AARP ABLE ANPPM ES EWGIIMatureNAPCA NCBA NCOA NOWCC NULI OPERABLESER SSAITWPA4TD Total Alabama 000 1840000000000 41400598 Alaska 000000000000000000 Arizona 00 147 1680000000000000315 Arkansas 1900000000 39700000000587 California 00 5990000 4460 375 20800 8290002 457 Colorado 146000000000000 180000326 Connecticut 000000000000000 3540354 Delaware 000000000000000000 District of Col 00 5500000 13000000000185 Florida 1 1320000000 36200 408000001 902 Georgia 21700000000 4980000000715 Hawaii 000000000000000000 Idaho 0000 155000000000000155 Illinois 0 1200 1740 820 360 9200000 365001 193 Indiana 203 63000 38800000000 19000844 Iowa 148 188000000000000 7700413 Kansas 0000000000000 318000318 Kentucky 00000 271000 2200 12000000611 Louisiana 00 49300000000000000493 Maine 0000000000000000 199199 Maryland 00000000000000 44300443 Massachusetts 0000000000003490 31100660 Michigan 00000000 80200 224000001 026 Minnesota 0000 191000000000 55800749 Mississippi 00000000 16600000 23100397 Missouri 2630000 17000 2260000 116000775 Montana 0000 201000000000000201 Nebraska 0 238000000000000000238 Nevada 1580000000000000000158 New Hampshire 0000000000001550000155 New Jersey 000 29900000 3850 22700000911 New Mexico 00000 15500000000000155 New York 000 222000 920 2140 29500 520 297 4332 073 North Carolina 00000000 179 2130000 45100843 North Dakota 0000 193000000000000193 Ohio 25800 1330 252 4730 142 14800000001 406 Oklahoma 000 3870000000000000387 Oregon 000 4740000000000000474 Pennsylvania 3400 121000000 5520 157000 352 1681 690 Puerto Rico 16700000000 2760000000443 Rhode Island 000000000000000 1710171 South Carolina 00000 43900000000000439 South Dakota 0000 200000000000000200 Tennessee 000000000 1500000 50900659 Texas 1 017000000000000 313 404001 734 Utah 000 2150000000000000215 Vermont 0000000000000000 176176 Virginia 2200000 259000 2020000000681 Washington 2520000 16600000000000418 West Virginia 000000000 3620000000362 Wisconsin 0000000000000 567 23300800 Wyoming 0000 155000000000000155 Total 4 711 609 1 415 2 256 1 095 2 182 473 898 2 496 3 595 208 1 431504 2 323 4 706 1 174 976 31 052 Based on cost per position of 9 698 with enacted minimum wage increase effective 7 24 09 Attachment IC U. S. Department of Labor Employment Training AdministrationSenior Community Service Employment Program PY 2020 Authorized Funding 4 Months for Non-Minority National Sponsors by State StateAARPABLEANPPMESEWGIIMatureNAPCANCBANCOANOWCCNULIOPERABLESERSSAITWPA4TDTotal Alabama 0 0 0 594 345 0 0 0 0 0 0 0 0 0 0 1 337 275 0 0 1 931 620 Alaska 0 0000000000000000 0 Arizona 0 0474 593542 3930000000000000 1 016 986 Arkansas 614 653 00000001 284 30100000000 1 898 954 California 0 01 936 75400001 442 05701 212 492672 529002 680 416000 7 944 248 Colorado 472 040 000000000000581 967000 1 054 007 Connecticut 0 000000000000001 145 4700 1 145 470 Delaware 0 0000000000000000 0 District of Col 0 0178 04200000420 82600000000 598 868 Florida 3 660 148 00000001 170 471001 319 20500000 6 149 824 Georgia 701 241 000000001 609 2990000000 2 310 540 Hawaii 0 0000000000000000 0 Idaho 0 000502 026000000000000 502 026 Illinois 0 387 9340562 5040265 08801 163 801297 416000001 179 96500 3 856 708 Indiana 656 300 203 6790001 254 40700000000614 27100 2 728 657 Iowa 478 377 607 668000000000000248 88500 1 334 930 Kansas 0 0000000000001 027 874000 1 027 874 Kentucky 0 0000876 059000711 1920387 92300000 1 975 174 Louisiana 0 01 594 07600000000000000 1 594 076 Maine 0 000000000000000642 421 642 421 Maryland 0 00000000000001 432 92600 1 432 926 Massachusetts 0 000000000001 128 51001 005 63500 2 134 145 Michigan 0 00000002 592 53700724 10000000 3 316 637 Minnesota 0 000617 5250000000001 804 07800 2 421 603 Mississippi 0 0000000537 23900000747 60400 1 284 843 Missouri 850 604 0000549 82000730 9370000375 171000 2 506 532 Montana 0 000648 955000000000000 648 955 Nebraska 0 770 906000000000000000 770 906 Nevada 511 760 0000000000000000 511 760 New Hampshire 0 00000000000502 0260000 502 026 New Jersey 0 00967 049000001 245 1970734 18100000 2 946 427 New Mexico 0 0000502 02600000000000 502 026 New York 0 00717 595000297 3820691 7350953 560001 680 852960 0251 399 633 6 700 782 North Carolina 0 0000000578 932688 89700001 458 65100 2 726 480 North Dakota 0 000625 000000000000000 625 000 Ohio 833 979 00429 9190814 5841 528 9610459 011478 4060000000 4 544 860 Oklahoma 0 001 252 1770000000000000 1 252 177 Oregon 0 001 533 1010000000000000 1 533 101 Pennsylvania 1 099 236 0391 1990000001 784 6420507 5880001 138 032543 152 5 463 849 Puerto Rico 540 178 00000000892 7490000000 1 432 927 Rhode Island 0 00000000000000553 1360 553 136 South Carolina 0 00001 419 86000000000000 1 419 860 South Dakota 0 000646 777000000000000 646 777 Tennessee 0 00000000484 77800001 645 01300 2 129 791 Texas 3 287 596 0000000000001 011 8171 305 98700 5 605 400 Utah 0 00694 6860000000000000 694 686 Vermont 0 000000000000000570 557 570 557 Virginia 711 254 0000837 340000653 0600000000 2 201 654 Washington 815 293 0000537 05800000000000 1 352 351 West Virginia 0 000000001 171 6020000000 1 171 602 Wisconsin 0 0000000000001 833 612753 49500 2 587 107 Wyoming 0 000502 026000000000000 502 026 Total 15 232 6591 970 1874 574 6647 293 7693 542 3097 056 2421 528 9612 903 2408 071 67011 624 049672 5294 626 5571 630 5367 510 85715 214 6373 796 6633 155 763100 405 292 Based on cost per position of 9 698 with enacted minimum wage increase effective 7 24 09 Attachment ID U. S. Department of Labor Employment Training Administration Senior Community Service Employment Program PY 2020 Authorized Positions for Minority National Sponsors by State StateIIDNAPCANICOATotal Alabama 0000 Alaska 0000 Arizona 00119119 Arkansas 470047 California 020934243 Colorado 0000 Connecticut 0000 Delaware 0000 District of Col 0000 Florida 0000 Georgia 0000 Hawaii 0000 Idaho 0000 Illinois 062062 Indiana 0000 Iowa 0000 Kansas 0000 Kentucky 0000 Louisiana 920092 Maine 0000 Maryland 0000 Massachusetts 075075 Michigan 0000 Minnesota 001919 Mississippi 370037 Missouri 0000 Montana 0000 Nebraska 0000 Nevada 0000 New Hampshire 0000 New Jersey 0000 New Mexico 003737 New York 057057 North Carolina 0000 North Dakota 001414 Ohio 0000 Oklahoma 008989 Oregon 0000 Pennsylvania 053053 Puerto Rico 0000 Rhode Island 0000 South Carolina 0000 South Dakota 003131 Tennessee 0000 Texas 3255087 Utah 0000 Vermont 0000 Virginia 0000 Washington 056056 West Virginia 0000 Wisconsin 001717 Wyoming 0000 Total2085673601 135 Based on cost per position of 9 698 with enacted minimum wage increase effective 7 24 09 Attachment IE U. S. Department of Labor Employment Training Administration Senior Community Service Employment Program PY 2020 Authorized Funding 4 Months for Minority National Sponsors by State StateIIDNAPCANICOA Total Alabama 0 0 0 0 Alaska 0000 Arizona 00384 775384 775 Arkansas 151 97000151 970 California 0675 782109 936785 718 Colorado 0000 Connecticut 0000 Delaware 0000 District of Col 0000 Florida 0000 Georgia 0000 Hawaii 0000 Idaho 0000 Illinois 0200 4710200 471 Indiana 0000 Iowa 0000 Kansas 0000 Kentucky 0000 Louisiana 297 47300297 473 Maine 0000 Maryland 0000 Massachusetts 0242 5060242 506 Michigan 0000 Minnesota 0061 43561 435 Mississippi 119 63600119 636 Missouri 0000 Montana 0000 Nebraska 0000 Nevada 0000 New Hampshire 0000 New Jersey 0000 New Mexico 00119 636119 636 New York 0184 3040184 304 North Carolina 0000 North Dakota 0045 26845 268 Ohio 0000 Oklahoma 00287 773287 773 Oregon 0000 Pennsylvania 0171 3710171 371 Puerto Rico 0000 Rhode Island 0000 South Carolina 0000 South Dakota 00100 236100 236 Tennessee 0000 Texas 103 469177 8370281 306 Utah 0000 Vermont 0000 Virginia 0000 Washington 0181 0710181 071 West Virginia 0000 Wisconsin 0054 96854 968 Wyoming 0000 Total672 5481 833 3421 164 0273 669 917 Based on cost per position of 9 698 with enacted minimum wage increase effective 7 24 09 Attachment II II-1 Senior Community Service Employment Program SCSEP Budget Narrative Instructions Program Year 2020 Grantees must provide a detailed budget narrative that includes the information outlined below. 1. Detailed Description of Costs on SF-424A Budget Information Form Section 6 Object Class Categories . Provide a detailed description for each line item on the SF-424A and ensure that each line item in the Budget Narrative indicates the same dollar amount as on the SF-424A. a. Personnel. Refers to wages salaries paid to employees of the grantee who are directly involved in grant implementation. This line item does not include personnel hired by the sub-grantee those costs are included in the Contractual line item. Provide the following information i. Position Include titles for all SCSEP staff positions and they must match the information provided in the program narrative. If there is more than one employee in the same position at the same salary level and employed for the same period of time enter each employee on a separate line. ii. Percent of Time List the percent of time each staff person will devote to the project. For example if a staff person were full-time but only spending 75 percent of their time on the project indicate .75 FTE full-time equivalent . iii. Monthly Salary Enter the average monthly salary not the average full time salary. Since pay periods vary from organization to organization the average would be the annual total salary divided by 12 months. If you expect that an employee will receive a salary increase during the grant period figure the average monthly salary for the entire year based on the sum of the two salary figures for the number of months the employee will receive each salary. iv. Number of Months Enter the projected number of months an employee will fill the position during the grant period. v. Cost The total cost equals Percent of Time times Monthly Salary Wage times Number of Months . b. Fringe Benefits. Refers to the cost of benefits paid to the personnel on the grant including the cost of employer s share of FICA health insurance workers compensation and leave. Provide a detailed list of the benefits provided to employees as well as the fringe benefit percentage i. Positions that receive fringe benefits. ii. Benefits The type of benefits that you will provide employees. If multiple benefits are included in the base amount list each of them in a separate row. iii. Rate Include the fringe benefit rate used to calculate benefits for each source. If the list of fringe benefits is itemized list the source for each item. iv. Base Amount Enter the Gross Salary used against the rate for the salary or salaries you are calculating. v. Cost The total cost is Rate times Base Amount . c. Travel. Refers to personnel travel costs that are reasonable and necessary to effectively manage and carry out grant activities provide oversight or measure program effectiveness such as mileage plane fare meals and incidentals and lodging . When air Attachment II II-2 travel is necessary obtain it at the lowes t possible customary standar d coach or equivalent fare . You may charge travel costs on an actual basis or on a per -diem or mileage basis in lieu of actual costs . This line item does not include a sub -recipient s travel expenses those costs are include d in the Contractual line item . Provide a narrative describing the purpose of the travel and the assumptions used to generate the travel amounts . Enter e ach typ e of travel cost mileage pe r diem etc . on separate lines . i. Item Briefly describe the t ravel item you will charge to the grant . Remember to enter travel for contracted employees under the Contractual category . ii. Number of Staff Provide the number of staff who will charge this type of travel . iii. Number of Units Provide the number of units you estimate you will charge to the grant per traveler staff for the year . iv. Cost per Unit Provide the cost of the travel item per traveler . If calculating based on mileage enter the cost per mile . v. Cost The total cost is Number of Staff times Numbe r of Units times Cost per Unit . d. Equipment . Refers to non -expendable personal property that has a useful life of more than one year and a per -unit cost of 5 000 or more . The only type of equipment that you may acquire with f ederal funds is equipment n ecessary for the operation of the grant . In the instance of a purchase prorate the cost of the equipment over the projected life of the equipment to determine the cost to the grant . Use of grant funds to purchase equipment with a unit cost of 5 000 or more requires specia l review and approval from the grant officer prior to purchase . Include necessary s hipping delivery and ins tallation in the budgeted amount . If you wish to obtain approval for the purchase of equipment at the time of your grant pro posal submission state this in the Bud get Narrative and provide the following information an explanation of how this equipment will be used to further the grant s objectives a justification for the need for the equipment the basis for valuation of the equipment and a description of the equipment to be purchased . If the grant officer approves the equipment your grant approval letter will state this . Otherwise you must make a subseq uent written request to the grant o fficer for approval . e. Supplies . Refers to all consumable materials costing l ess than 5 000 per unit such as copy pap er pens and pencils computers any training mate rials agreements for evaluating the grant or providing training . Include t he total supply costs of all su b-grant cont racts in this line item . Charge supply purchases to the grant at their actual prices after deducting all cash discounts trade disc ounts rebates or allowances . Include any necessary shipping and delivery costs . Lump supplies under larger categorical h eadings and provide detailed information on computations justifying the respective amounts . Indicate the basis for all estimates . f. Contractual . Refers to the cost of any contract or sub -grant agreement . Include t he cost of any contract or sub -grant agr eement between the grantee and another organization i.e. vendor . Examples of contractual costs are sub -agreements for evaluating the grant providing training maintenance contrac ts or other service contracts . Provide the name of the vendor if known an explanation of the services that will be provided under the contract or sub -agreement and the contracted amount . Include information about what Attachment II II-3 specific fringe benefits you will charge to the grant including the fringe benefit percentage . g. Constructi on . SCSEP regulations typically do not allow expenditures for co nstruction 20 CFR 641 .850 e . h. Other . Refers to items that do not fit under any of the other cost categories such as rent utilities supportive services and training tuition costs . If y ou have items under this category itemize them along with an explanation and justification for the items . i. Total Direct Cost . The sum of lines a through h . j. Indirect Cost . Refers to costs incurred for common o r joint objectives that benefit more than one project . They may originate in your unit or in other part s of your organization that supp ly goods services or facilitie s to the SCSEP grant . Most often the term indirect costs indicate s costs incurred to support the overall operation of the organiza tion . Indirect costs may be both administrative and programmatic . If you have a single funding source then you do not need an indirect cost rate . If you have multiple funding sources espec ially f ederal funding sources that support the operations and activities of the organizat ion you need an indirect cost rate . An indirect cost rate equitably distributes cost s to all benefiting activities . It provides for the systematic allocation of indirect cost -to-cost objectives in reasonable proportion with the benefits received . These costs are not readily assignable to specific awards and activities because a direct relationship to cost objectives such as grants contracts fundra ising or services to members cann ot be shown or would be arbitrary in natur e. If you have an approved indirect cost rate include a copy of the indirect cost agreement or cost allocation plan signed by the issuing Federal agency as an at tachment to the grant proposal . Organizations with no pri or approved indirect cost rate t hat intend to ch arge in direct costs to the grant must develop an indirect cost rate proposal and submit it to a cognizant agency no later than 90 days afte r the effective date of the agreement . k. Totals . The sum of lines i and j . 2. Participant Wages and Fri nge Benefits . You must clearly list both the percentage and total fundin g dollar amount allocated to participant wages and fringe benefits as defined at 20 CFR 641 .565 in the appropriate section of the SF -424A . The SF -424A does not have a line item exclu sively for participant wages and fringe benefits . In most cases list participant wages and fringe benefits on the Contractual or Other line . 3. Administrative C osts . You must clearly list both the percentage and total funding dollar amount allocated to administrative costs as described at 20 CFR 641 .856 . In general SCSEP has a maximum allowed administrative costs total of 13 .5 percent of the federal grant funds or up to 20 percent if you have requested and received approval from ETA per the instru ctions in Attachment V . The SF -424A does not have a line item for Administrative Attachment II II-4 costs . Because your administrative costs may come from multiple line items you must clearly itemize and summarize your administrative costs separately . 4. Infrastructure C ontributions to the Workforce S ystem . You must clearly identify your infrastructure contribut ions to the workforce system . WIOA Sec . 121 h describes the responsibilities of required partners including SCSEP . Training and Employment Guidance Letter TEGL 17 -16 Infrastructure Funding of the One -Stop Delivery System outlines how one -stop partners must determine and pay for infrastructure and additional costs in the local one -stop delivery systems . The SF -424A does not have a line item exclusively f or infrastructure contributions . List your infrastructure contributions on the Administrative Contractual or Other line as appropriate . If you are not paying any infrastructure contributions into the workforce system explain why you are not doin g so in the Budget and Program Narrative . This explanation alone does not relieve any SCSEP grantee from the requirements of WIOA Sec . 121 h but ETA will review an explanation before further discussions with a grantee . Attachment III .a III.a-1 Senior Community Service Employment Pr ogram SCSEP Program Narrative Instructions Program Year 2020 SCSEP State and Territory Grantees All SCSEP state and territory grantees must provide a program narrative that concisely covers the areas below. Sta te and territory grantees may use PY 2020 State Plan submissions to provide the following if it meets the criteria below. State and territory grantees that submitted WIOA Combined State Plans and SCSEP stand -alone plans may copy and paste th at portion of their State Plan and attach it as applicable . 1. Services to Minorities OAA Title V Section 515 . The minority report does not have participation and enrollment data for the three Pacific territories and the U.S. Virgin Islands these four grantees will answer the questions in terms of outcomes only. All other grantees must describe efforts to serve individuals from minority populations as well as any disparities in those participants outcomes. Using the PY 201 8 SCSEP Minority Report an interim report was distributed to grantees via email on March 12 2020 for PY 2020 grant planning purposes as well as SPARQ and InfoSPACE data for PY 20 19 grantees must describe Any significant disparities in enrollment levels or performance outcomes for minority individuals identified in the PY 201 8 report the extent to which those disparities existed in prior years and the extent to which they continue to exist. Include a. The factors that may have caused these disparities in enrollment and outcomes and b. The steps you have already taken and or plan to take to address any under -service or disparities in outcomes for minorities. 2. Organizational Structure Monitoring and Audits Uniform Administrative Guidance 2 CFR part 200 . Describe the structure of your SCSEP pr oject and explain how you will effectively manage any subprojects. Ensure that these descriptions are consistent with the information in your Budget Narrative. Include a. A description of your SCSEP key staff including experience implementing SCSEP prima ry responsibilities and the amount of time each indi vidual is assigned to the grant. If you have sub -recipients or local affiliates include a table with their names locations the number of authorized positions for which they are responsible and their years of experience implementing SCSEP b. A legible SCSEP organizational chart may be an attachment that depicts key SCSEP staff and includes sub -recipients or local affiliates involved in implementing the grant including host agencies c. A description of how you ensure that policies procedures and other important information are communicated and implemented throughout the program and a description of how training will be provided to local staff sub -recipients or affiliates and d. A description of how y ou will monitor projects for program and financial compliance . Attachment III.b III.b-1Senior Community Service Employment Program Grantee Statement of Work for PY 2020 Funding Current SCSEP National Grantees Senior Community Service Employment Program SCSEP grantees awarded funds for Program Year PY 2020 will use these funds to provide eligible unemployed low-income seniors with training to acquire the skills necessary to secure employment. The subsidized wages paid to participants provide needed income to seniors 55 and older with an added benefit to their communities from their service. Authority for Funding Activities and Reporting The Department of Labor expects grantees to adhere to the current statutory and regulatory requirements for SCSEP as contained in the following Funding Opportunity Announcement FOA-ETA-20-09 April 30 2020 TEGL 22-19 Program Year PY 2020 Planning Instructions and Allotments for Senior Community Service Employment Program SCSEP State Territory and National Grantees and Implementation of SCSEP Provisions of the Coronavirus Aid Relief and Economic Security Act CARES Act May 28 2020 OAA Reauthorization Act of 2016 Pub. L. 114-144 April 19 2016 Further Consolidated Appropriations Act of 2020 Pub. L. 116-94 December 20 2019 SCSEP Final Rule 75 Federal Register FR 537864 September 1 2010 published at 20 CFR Part 641 TEGL 17-16 Infrastructure Funding of the One-Stop Delivery System January 18 2017 WIOA Pub. L. 113-128 Sec. 121 Funding of One-Stop Infrastructure Paperwork Reduction Act of 1995 Pub. L. 104-13 May 22 1995 SCSEP Performance Data Collection Approval Office of Management and Budget No. 1205-0040 expiration date November 30 2021 OMB Uniform Administrative Requirements Cost Principles and Audit Requirements for Federal Awards Final Rule 78 FR 78589 December 26 2013 published at 2 CFR Part 200 TEGL 12-06 Revised Income Inclusions and Exclusions and Procedures for Determining Senior Community Service Employment Program SCSEP Eligibility December 28 2006 VOW Veterans Opportunity to Work to Hire Heroes Act of 2011 Pub. L. 112-56 November 21 2011 The Fair Labor Standards Act of 1938 as amended through Pub. L. 115-141 March 23 2018 2020 Federal Poverty Guidelines 85 FR 3026 January 15 2020 and The Social Security Act of 1935 as amended through Pub. L. 89-97 July 30 1965 . Attachm ent III.b III.b -2 Grantee Activities Accountabil ity and transparency for use of PY 2020 funds are ensured through the following grantee activities Track participation and document program activitie s and directly enter data using the SCSEP Performance and Results QPR SPARQ data collection and performance reporting system Provide SCSEP services within the counties geographic areas only as authorized in accordance with Program Year Equitable Distr ibution Develop and maintain appropriate management strategies to deal with fluctuations in funding including recruitment and enrollment policies and manage grant finds so as to avoid fluctuations in the number of hours per week in community service p rovided to participants Evaluate and adhere to termination policies as appropriate Ensure grievance policies are clear and available to all applicants and participants Recruit new host agencies and expand opportunities at existing host agencies Ma intain individual durational limit IDL policies that ensure equitable and uniform practices for all SCSEP participants reaching their individual participation durational limits in PY 2020 including transition strategies with any revised IDL policy appr oved by DOL to take effect no sooner than 120 days after approval Monitor and report efforts to serve minority individuals Protect against maintenance of effort violations Track all SCSEP grant funds and submit all required financial reports in a time ly manner as determined by the Department of Labor USDOL and Follow Programmatic A ssurances as prescribed. Ensure the least disruption for participants transitioning in to and out of service areas. The submission of an SF -424 Application for Federal Ass istance signed by the grantee s authorized representative an SF -424A with a Budget Narrative Program Narrative and signed Programmatic Assurances and any Optional Special Requests constitute acceptance of this Generic Statement of Work and the issuance of a PY 2020 grant agreement. Attachment IV IV-1 Senior Community Service Employment Program SCSEP Programmatic Assurances Program Year 2020 You must certify that you will conform to these assurances throughout the period of the grant by checking each of the assurances below. These assurances apply fully to any sub-recipient local project or grantee staff involved in the delivery of services. You agree to Recruitment and Selection of Participants Develop and implement methods to recruit and select eligible participants to assure maximum participation in the program. Use income definitions and income inclusions and exclusions for SCSEP eligibility as described in TEGL No. 12-06 to determine and document participant eligibility. Develop and implement methods to recruit minority populations to ensure at least proportional representation in your assigned service area as listed in the latest Minority Report. Develop and implement strategies to recruit applicants who have priority of service as defined in Older Americans Act section 518 b 1 - 2 and by the VOW Veterans Opportunity to Work to Hire Heroes Act of 2011. Individuals with priority are those who Are covered persons in accordance with the VOW covered persons who are SCSEP- eligible must receive services instead of or before all non-covered persons Are 65 years or older Have a disability Have limited English proficiency Have low literacy skills Reside in a rural area Have low employment prospects Have failed to find employment after utilizing services provided under Title I of the Workforce Innovation and Opportunity Act WIOA or Are homeless or are at risk for homelessness. Assessment Assess participants at least twice per 12-month period or more frequently if appropriate. Use assessment information to determine the most appropriate community service assignments for participants. Attachment IV IV-2 Individual Employment Plan IEP Establish an initial goal of unsubsidized employment for all participants. Update the IEP at least as frequently as assessments occur at least twice per 12 -month peri od . Modify the IEP as necessary to reflect other approaches to self -sufficiency if it becomes clear that unsubsidized employment is not feasible. For participants who will reach the individual durational limit or would not otherwise achieve unsubsidize d employment include a provision in the IEP to reflect other approaches to self -sufficiency transition to other services or programs. Rotate participants to a new host agency or a different assignment within the host agency based on a rotation policy approved by the Employment and Training Administration ETA in the grant agreement and only after making an individualized determination that the rotation is in the best interest of the participant. Such rotation must further the acquisition of skills lis ted in the IEP. Community Service Assignment Base the initial community service assignment on the assessment made at enrollment. Select only designated 501 c 3 organizations or public agencies as host agencies. Put in place procedures to ensure adequate supervision of participants at host agencies. Ensure safe and healthy working conditions at the community service assignment through annual monitoring of the host agency site and annual safety consultation with the participant at the host agency site. Re certification of Participants Recertify the income eligibility of each participant at least once every 12 months or more frequently if circumstances warrant. Physical Examinations Offer physical examinations to participants upon program entry and each y ear thereafter as a benefit of enrollment. Obtain a written waiver from each participant who declines a physical examination. Not obtain a copy or use the results of the physical examination to establish eligibility or for any other purpose. Attachment IV IV-3 Host Agenci es Develop and implement methods for recruiting new host agencies to provide a variety of training options that enable participants to increase their skill level and transition to unsubsidized employment. Comply with maintenance of effort Ensure that co mmunity service assignments do not reduce the number of employment opportunities or vacancies that would otherwise be available to individuals who are not SCSEP participants. You must specifically ensure that community service assignments do not Displace currently employed workers including partial displacement such as a reduction in non -overtime work wages or employment benefits . Impair existing contracts or result in the substitution of Federal funds for other funds in connection with work that wou ld otherwise be performed. Assign or continue to assign a participant to perform the same work or substantially the same work as that performed by an individual who is on layoff. Orientation Provide orientations for participants and host agencies inclu ding information on Project goals and objectives Participant rights and responsibilities Community service assignments Opportunities for paid training outside the community service assignment Available supportive services Availability of free physical exa minations Local staff must address the topics listed above and provide additional orientation to participants on SCSEP goals and objectives Grantee and local project roles policies and procedures Holiday and sick leave Assessment process Development and implementation of IEPs Evaluation of participant progress Health and safety issues related to each participant s assignment Role of supervisors and host agencies Maximum individual duration policy including the possibility of an extension if applicable and the documentation required to support an extension Termination policy Grievance procedure Attachment IV IV-4 Wages Provide participants with the highest applicable required wage highest of Federal state or local minimum wage for the most nearly comparable covered em ployment or minimum wage under the Fair Labor Standards Act of 1938 or the prevailing rate of pay for persons employed in similar public occupations by the same employer for time spent in orientation training and community service assignments. Partici pant Benefits Provide workers compensation other benefits required by state or Federal law such as unemployment insurance and the costs of physical examinations. Provide compensation for scheduled work hours during which the participant s host agency is closed for Federal holidays which may be paid or in the form of rescheduled work time and establish written policies related to this compensation. Establish written policies relating to approved breaks in participation and any necessary sick leave t hat is not part of an accumulated sick leave program. Not use grant funds to pay the cost of pension benefits annual leave accumulated sick leave or bonuses. Procedures for Payroll and Workers Compensation Make all required payments for participant p ayroll and pay workers compensation premiums on a timely basis. Ensure that host agencies do not pay workers compensation costs for participants. Durational Limits Maximum Average Project Duration - 27 Months Maintain average project duration of 27 mon ths or less unless ETA approves an extension to 36 months except as increased as allowed under the SCSEP provisions of the CARES Act. Maximum Individual Participant Duration - 48 Months Allow participants to participate in the program no longer than 48 months whether or not consecutively unless your approved policy allows for an extension and the participant meets the extension criteria and except as extended as allowed under the SCSEP provisions of the CARES Act. Attachment IV IV-5 Notify participants of your policy pertaining to the maximum duration requirement including the possibility of an extension if applicable at the time of enrollment and each year thereafter and whenever ETA has approved a change of policy. Provide 30 -day written notice to participants pr ior to durational limit exit from the program. Transition Services Develop a system to transition participants to unsubsidized employment or other assistance before each participant s maximum enrollment duration has expired. Begin transition planning for participants who will exit for durational limit at least 3 -6 months prior to their exit date. Termination Policies Provide a 30 -day written notice for all involuntary terminations that states the reason for termination and informs the participants of gri evance procedures and right to appeal. Maintain written termination policies in effect and provide to participants at enrollment Provision of false eligibility information by the participant Incorrect initial eligibility determination at enrollment Incom e ineligibility determined at recertification Participant has reached individual durational limit Participant has become employed while enrolled IEP -related termination Cause must be approved by ETA prior to implementation Equitable Distribution Comply with the equitable distribution plan for each state in which the grantee operates and only make changes in the location of authorized positions within a state in accordance with the state equitable distribution plan and with prior ETA approval. Comply wit h the authorized position allocations equitable distribution listed at www.scseped.org. Collaborate with all grantees authorized to serve in a state in which you operate to achieve compliance with authorized positio ns while minimizing disruption to the participants. Over -Enrollment Manage over -enrollment to minimize impact on participants and avoid layoffs. Attachment IV IV-6 Administrative Systems Ensure representation at all ETA -sponsored required grantee meetings. Communicate grant policy data collection and performance developments and directives to staff sub -recipients and local project operators on a regular basis. Develop a written monitoring tool that lists items you will review during monitoring visits and provide this t ool to sub -recipients and local project operators. Develop an annual monitoring schedule unless the federal project officer approves a different standard notify sub -recipients and local project operators of monitoring plans and monitor sub recipients a nd local project operators on a regular basis. Develop and provide training to increase sub -recipients and local project operators skills knowledge and abilities. When appropriate prescribe corrective action and follow -up procedures for sub recipien ts and local project operators to ensure that identified problems are remedied. Monitor the financial systems and expenditures including sub -recipients and local project operators on a regular basis to ensure compliance with cost allocations as specified in the regulations. Ensure that sub -recipient and local project operators receive adequate resources to effectively operate local projects. Train sub -recipients and local project operators on SCSEP financial requirements to help them effectively manage their own expenditures and provide general financial training as needed. Ensure that all financial reports are accurate and submit them in a timely manner as required . Ensure full implementation and monitoring of requirements for customer satisfaction surveys including participant host agency and employer surveys. Develop a written plan for both disaster response and recovery so that the project may continue to operate and provide services under emergency circumstances. Collaboration and Leveraged R esources Collaborate with other organizations to maximize opportunities for participants to obtain workforce development education and supportive services to help them move into unsubsidized employment. These organizations may include but are not limite d to workforce developme nt boards American Job Centers vocational rehabilitation providers disability networks basic education and literacy providers and community colleges. Attachment IV IV-7 Supportive Services Provide supportive services as needed to help partici pants participate in their community service assignment and to obtain and retain unsubsidized employment. Establish criteria to assess the need for supportive services and to determine when participants will receive supportive services including after ob taining unsubsidized employment. Sub -Recipient Selection If Applicable In selecting sub -recipients in areas with a substantial population of individuals with barriers to employment national grantees will give special consideration to organizations with demonstrated expertise in serving individuals with barriers to employment including former recipients of national grants as defined in the statute. Complaint Resolution Establish and use written grievance procedures for complaint resolution for applic ants employees sub -recipients and participants. Provide applicants employees sub -recipients and participants with a copy of the grievance policy and procedures. Maintenance of Files and Privacy Information Maintain participant files for three progr am years after the program year in which the participant received his her final follow -up activity. Ensure that all participant records are securely stored by the grantee or sub -recipient and access is limited to appropriate staff in order to safeguard pe rsonal identifying information. Ensure that all participant medical records are securely stored by the grantee or sub - recipient separately from all other participant records and access is limited to authorized staff for authorized purposes. Establish saf eguards to preclude tampering with electronic media e.g. personal identification numbers and SPARQ or other data system logins . Ensure that ETA SCSEP national office is immediately notified in the event of any potential security breach of personal iden tifying information whether electronic files paper files or equipment are involved. Comply with and ensure that authorized users under the grant comply with all SPARQ and other data system access and security rules. Attachment IV IV-8 Documentation Maintain all document ation required for compliance with record retention rule set forth in the first bullet of the prior section Maintenance of Files and Privacy Information . Maintain documentation of waivers of physical examinations by participant. Maintain documentation of the provision of complaint procedures to participants. Maintain documentation of eligibility determinations and re -certifications. Maintain documentations of terminations and reasons for termination. Maintain records of grievances and outcomes. Maintain r ecords required for data validation. Maintain documentation of monitoring reports for sub -recipients and host agencies. Data Collection and Reporting Ensure the collection and reporting of all SCSEP required data according to specified time schedules. En sure the use of the Office of Management and Budget -approved SCSEP data collection forms and the SCSEP Internet data collection and evaluation system SPARQ or the successor data system as designated by ETA. Ensure at the grantee or sub -recipient level t hat those capturing and recording data are familiar with the latest instructions for data collection including ETA administrative issuances e.g. Training and Employment Guidance Letters Data Collection and Data Validation Handbooks and the Older Worke r Community of Practice . Ensure data are entered directly into the WDCS SPARQ or the successor data system as designated by ETA. Legally obligate sub -recipients to tu rn over complete data files in the specified electronic format as well as hard copy c ase files to the grantee when sub -recipients cease to administer SCSEP. Legally obligate new sub -recipients to collect and enter complete data related to any participants whom they acquire upon becoming sub -recipients including any participants who are still in the follow -up period. If the grantee is not in compliance with any of the as surances above provide information on a separate attachment indicating what specific steps the grantee is taking to conform to these standard grant requirement s . Attachment IV IV-9 The signature of the Authorized Representative on the SF -424 of this grant application also certifies that the organization agrees to adhere to the programmatic assurances listed above in this Attachment IV . Attachment V V-1 Instructions for Senior Community Service Employment Program SCSEP Optional Requests Program Year 2020 Grantees that wish to make optional requests must submit each request in a separate clearly- titled document. To receive Employment and Training Administration ETA approval requests must adhere to the statute and regulations and provide a substantive rationale such as improved program management better service to participants or least disruption possible to participants. 1. Change 48-Month Individual Durational Limit IDL 20 CFR 641.570 a 3 . This section is relevant only if you are requesting a change. To change your current IDL policy you must request and receive ETA approval for one of the IDL policies listed below. Note that the IDL request process reflected here is separate from and in addition to the IDL extensions allowed under the CARES Act. If a grantee changes the current IDL policy to a more restrictive policy it must have an effective date of at least 120 days after written approval from ETA. If you propose to change the existing IDL policy you must describe a. Your current ETA-approved IDL policy and procedure. b. Which of the options below you propose to adopt i. Option 1 No extensions for any participants all participants exit at 48 months. ii. Option 2 Extensions to every participant who meets at least one of the seven waiver factors. Indicate the length of the extension e.g. one-time twelve-month only unlimited three times only . iii. Option 3 Extensions to every participant who meets a specific subset of the seven waiver factors. Indicate the length of the extension e.g. one-time twelve- month only unlimited three times only . c. A reasonable transition plan that addresses when and how you will notify participants of the change and the planned activities to prepare participants for exit from the program. 2. Additional Funds for Participant Training and Supportive Services ATSS Older Americans Act OAA Section 502 c 6 C . Approvals for this option expire at the end of each program year--grantees must submit a new request for approval each year in order to exercise this option. Prepare your Budget Narrative so that it is consistent with your ATSS request. If ETA denies your request you must resubmit a revised SF- 424A and Budget Narrative. The OAA permits ETA to grant an exception to the 75 percent minimum level of expenditures on participant wages and fringe benefits. This exception allows you to use no less than 65 percent of program funds for participant s wages and fringe benefits so that up to an additional 10 percent of funds are available for training and supportive services that directly benefit participants. If you wish to request the use of additional funds for training and supportive services for Program Year 2020 you must provide a. A description of the activities for which you will spend the grant funds described in paragraph 20 CFR 641.874 a 3 an identification of the percentage of federal funds and the dollar amount that will be dedicated to the training and an assurance that any remaining grant funds will be used for participant training job placement assistance participant supportive services and outreach recruitment and selection intake Attachment V V-2 orientation and assessment 20 CFR 641.874 a 4 . b. A description of how the provision of such activities will improve the effectiveness of the project including i. An assurance that no displacement of eligible individuals or limitation of positions for such individuals will occur and ii. A description of whether the number of individuals served will be reduced a plan for meeting the service level goal and an estimate of how the activities will improve employment outcomes for the individuals served. c. A proposed budget and work plan for the activities including a detailed description of how the funds will be spent on the activities described in paragraphs a 3 and a 4 of 20 CFR 641.874. The budget and work plan must detail the additional training and supportive services that will be provided to SCSEP participants the associated cost for each activity and the number of participants who will benefit from the training. Please ensure that items described in the work plan are also in the Budget Narrative. d. Grantees with approved requests may choose to apply the provision uniformly to all sub-recipients but need not provide this opportunity to every sub-recipient. If you choose not to apply the provision uniformly to all sub-recipients you must provide a detailed description of how you will allocate the funds among sub-recipients and must include a detailed budget and work plan for each sub-recipient. 3. Increase in Administrative Cost Limitations 20 CFR 641.870 . Approvals for this option expire at the end of each program year--grantees must submit a new request for approval each year in order to exercise this option. Prepare your Budget Narrative so that it is consistent with your Administrative Cost Increase request. If ETA denies your request you must resubmit a revised SF-424A and Budget Narrative. As explained in the body of the TEGL in accordance with the CARES Act this TEGL provides grantees the opportunity to request to increase the administrative cost limitation to up to 20 percent of the grant amount if the grantee can demonstrate that such an increase will help it mitigate the impact of the COVID -19 public health emergency on its operations employees and or participants . Accordingly ETA will consider requests to authorize an increase in the amount available for administrative costs from 1 3.5 percent to no more than 20 percent if 1 we determine that it is necessary to carry out the project and 2 you demonstrate one of the following conditions a. Your project is incurring major administrative cost increases in necessary program components e.g. liability insurance payments for workers compensation for staff costs associated with achieving unsubsidized placement goals or other operation requirements imposed by the Department of Labor including any such increases due to COVID -19 b. The number of community service assignment positions or eligible minority individuals participating in your project that will decline if the amount available for paying the cost of administrative costs is not increased or c. The project size is so small that the amount of administrative expenses incurred to carry out the project necessarily exceeds 13.5 percent of the grant amount. Attachment V V-3 4. Extension of Average Pr oj ect Duration 20 CFR 641. 570 5 c 2 . Given the extension of Individual Durational Limits and the corre sponding increase in the Average Project Duration in accordance with the CARES Act as described in the body of this TEGL grantees need not submit requests to further extend the Average Project Duration. As also noted in the body of this TEGL Average P roject Durations will be automatically adjusted as needed to account for Individual Durational Limit extensions. 5. On -the -Job Experience OJE Training . Approvals for this option expire at the end of each program year --grantees must submit a new request f or approval each year in order to exercise this option. If you wish to utilize OJE you must address all of the requirements stipulated in Older Worker Bulletin 04 -04 https www.doleta. gov seniors Other docs 04 -04.pdf . You must also provide a copy of your OJE policy and sample contracts to ETA for approval before you can exercise this option. 6. Cross -Border Agreements 20 CFR 641.515 c . Approvals f or this option expire at the end of each program year --grantees must submit a new request for approval each year in order to exercise this option. State grantees may enter into agreements to permit cross - border enrollment of eligible participants. These agreements must cover both state and national grantee authorized positions and you must submit them to ETA for approval. 7. Rotation Policy 20 CFR 641.575 . Approvals for this option expire at the end of each program year --grantees must submit a new request for approval each year in ord er to exercise this option. You may establish a policy of rotating participants to a new host agency or a different assignment within the current host agency. Your policy must assure that you will make an individualized dete rm ination that a rotation is in the best interest of the participant and that rotation will f urt her the acquisition of ski lls listed in the participant s individual employment plan .