Attachment IV (Accessible PDF).pdf

ETA Advisory File Text

IV-1 Attachment IV Senior Community Service Employment Program SCSEP Programmatic Assurances Program Year 2025 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 o Develop and implement methods to recruit and select eligible participants to assure maximum participation in the program. o Use income definitions and income inclusions and exclusions for SCSEP eligibility as described in TEGL No. 12-06 to determine and document participant eligibility. o 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 as required at 20 CFR 641.515 a . The Secretary shall annually prepare a report on the levels of participation and performance outcomes of minority individuals served by the program carried out under this title. o 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 Are homeless or are at risk for homelessness or Are formerly incarcerated or on supervision from release from prison or jail within five years of the date of initial eligibility determination. Assessment o Assess participants at least twice per 12-month period or more frequently if appropriate. o Use assessment information to determine the most appropriate community service assignments for participants. Individual Employment Plan IEP o Establish an initial goal of unsubsidized employment for all participants. IV-2 o Update the IEP at least as frequently as assessments occur at least twice per 12-month period . o Modify the IEP as necessary to reflect other approaches to self-sufficiency if it becomes clear that unsubsidized employment is not feasible. o For participants who will reach the individual durational limit or would not otherwise achieve unsubsidized employment include a provision in the IEP to reflect other approaches to self-sufficiency transition to other services or programs. o 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 listed in the IEP. Community Service Assignment o Base the initial community service assignment on the assessment made at enrollment. o Select only designated 501 c 3 organizations or public agencies as host agencies. o Put in place procedures to ensure adequate supervision of participants at host agencies. o 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. Recertification of Participants o Recertify the income eligibility of each participant at least once every 12 months or more frequently if circumstances warrant. Physical Examinations o Offer physical examinations to participants upon program entry and each year thereafter as a benefit of enrollment. o Obtain a written waiver from each participant who declines a physical examination. o Not obtain a copy or use the results of the physical examination to establish eligibility or for any other purpose. Host Agencies o 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. o Comply with maintenance of effort Ensure that community 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 a. Displace currently employed workers including partial displacement such as a reduction in non-overtime work wages or employment benefits . b. Impair existing contracts or result in the substitution of Federal funds for other funds in connection with work that would otherwise be performed. c. 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. IV-3 Orientation o Provide orientations for participants and host agencies including information on a. Project goals and objectives b. Participant rights and responsibilities c. Community service assignments d. Opportunities for paid training outside the community service assignment e. Available supportive services and f. Availability of free physical examinations. o Local staff must address the topics listed above and provide additional orientation to participants on a. SCSEP goals and objectives b. Grantee and local project roles policies and procedures c. Holiday and sick leave d. Assessment process e. Development and implementation of IEPs f. Evaluation of participant progress g. Health and safety issues related to each participant s assignment h. Role of supervisors and host agencies i. Maximum individual duration policy including the possibility of an extension if applicable and the documentation required to support an extension j. Termination policy and k. Grievance procedure. Wages o Provide participants with the highest applicable required wage highest of Federal state or local minimum wage for the most nearly comparable covered employment 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. Participant Benefits o Provide workers compensation other benefits required by state or Federal law such as unemployment insurance and the costs of physical examinations. o 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. o Establish written policies relating to approved breaks in participation and any necessary sick leave that is not part of an accumulated sick leave program. o Not use grant funds to pay the cost of pension benefits annual leave accumulated sick leave or bonuses. Procedures for Payroll and Workers Compensation o Make all required payments for participant payroll and pay workers compensation premiums on a timely basis. IV-4 o Ensure that host agencies do not pay workers compensation costs for participants. Durational Limits Maximum Average Project Duration - 27 Months o Maintain average project duration of 27 months or less unless ETA approves an extension to 36 months. Maximum Individual Participant Duration - 48 Months o 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. o 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. o Provide 30-day written notice to participants prior to durational limit exit from the program. Transition Services o Develop a system to transition participants to unsubsidized employment or other assistance before each participant s maximum enrollment duration has expired. o Begin transition planning for participants who will exit for durational limit at least 3-6 months prior to their exit date. Termination Policies o Provide a 30-day written notice for all involuntary terminations that states the reason for termination and informs the participants of grievance procedures and right to appeal. o Maintain written termination policies in effect and provide to participants at enrollment a. Provision of false eligibility information by the participant b. Incorrect initial eligibility determination at enrollment c. Income ineligibility determined at recertification d. Participant has reached individual durational limit e. Participant has become employed while enrolled f. IEP-related termination and g. Cause must be approved by ETA prior to implementation . Equitable Distribution o 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. o Comply with the authorized position allocations equitable distribution listed at https scsepapply.org . o Collaborate with all grantees authorized to serve in a state in which you operate to achieve compliance with authorized positions while minimizing disruption to the IV-5 participants. Over-Enrollment o Manage over-enrollment to minimize impact on participants and avoid layoffs. Administrative Systems o Communicate grant policy data collection and performance developments and directives to staff sub-recipients and local project operators on a regular basis. o Develop a written monitoring tool that lists items you will review during monitoring visits and provide this tool to sub-recipients and local project operators. o 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 and local project operators on a regular basis. o Develop and provide training to increase sub-recipients and local project operators skills knowledge and abilities. o When appropriate prescribe corrective action and follow-up procedures for sub- recipients and local project operators to ensure that identified problems are remedied. o 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. o Ensure that sub-recipient and local project operators receive adequate resources to effectively operate local projects. o 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. o Ensure that all financial reports are accurate and submit them in a timely manner as required. o Ensure full implementation and monitoring of requirements for customer satisfaction surveys including participant host agency and employer surveys. o 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 Resources o 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 limited to workforce development boards American Job Centers vocational rehabilitation providers disability networks basic education and literacy providers and community colleges. Supportive Services o Provide supportive services as needed to help participants participate in their community service assignment and to obtain and retain unsubsidized employment. o Establish criteria to assess the need for supportive services and to determine when participants will receive supportive services including after obtaining unsubsidized employment. IV-6 Complaint Resolution o Establish and use written grievance procedures for complaint resolution for applicants employees sub-recipients and participants. o Provide applicants employees sub-recipients and participants with a copy of the grievance policy and procedures. Maintenance of Files and Privacy Information o Maintain participant files for three program years after the program year in which the participant received his her final follow-up activity. o 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 personal identifying information. o 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. o Establish safeguards to preclude tampering with electronic media e.g. personal identification numbers and GPMS or other data system logins . o Ensure that ETA is immediately notified in the event of any potential security breach of personal identifying information whether electronic files paper files or equipment are involved. o Comply with and ensure that authorized users under the grant comply with all GPMS and other data system access and security rules. Documentation o Maintain all documentation required for compliance with record retention rule set forth in the first bullet of the prior section Maintenance of Files and Privacy Information. o Maintain documentation of waivers of physical examinations by participant. o Maintain documentation of the provision of complaint procedures to participants. o Maintain documentation of eligibility determinations and re-certifications. o Maintain documentations of terminations and reasons for termination. o Maintain records of grievances and outcomes. o Maintain records required for data validation. o Maintain documentation of monitoring reports for sub-recipients and host agencies. Data Collection and Reporting o Ensure the collection and reporting of all SCSEP required data according to specified time schedules. o Ensure the use of the Office of Management and Budget-approved SCSEP data collection forms and the SCSEP Internet data collection and evaluation system GPMS or the successor data system as designated by ETA. o Ensure at the grantee or sub-recipient level that 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 Worker Community of Practice . IV-7 o Ensure data are entered directly into the GPMS or the successor data system as designated by ETA. o Legally obligate sub-recipients to turn over complete data files in the specified electronic format as well as hard copy case files to the grantee when sub- recipients cease to administer SCSEP. o 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 assurances above provide information on a separate attachment indicating what specific steps the grantee is taking to conform to these standard grant requirement s . 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. Signature of Authorized Representative Date