References: a. The North American Free Trade Agreement Implementation Act (P.L. 103-182). b. Excerpt from "Statement of Administrative Action" (attached). c. Job Training Partnership Act, as amended. d. General Administration Letter No. 7-94, dated December 28, 1993, entitled "Operating Instructions for Implementing the Amendments to the Trade Adjustment Assistance for Workers Program in Title V of the North American Free Trade Agreement (NAFTA) Implementation Act" (attached). Background: On December 8, 1993, the President signed into law the North American Free Trade Agreement Implementation Act (the Act). Title V of the Act provides for a NAFTA-Trade Adjustment Assistance (NAFTA-TAA) program under which assistance will be provided to workers in firms directly affected by imports from or shifts in production to Mexico or Canada. This program is similar in many ways to the existing Trade Adjustment Assistance program. The legislation requires that State Title III programs provide certain services with Title III funds after the Governor makes an affirmative preliminary finding on a petition filed by workers under NAFTA-TAA. In addition to the program of adjustment assistance provided in the Act, a separate program has been provided for in the "Statement of Administrative Action" which accompanied the Act and was approved in Section 101(a)(2). Through this Statement, a copy of which is attached, the Administration has agreed to provide adjustment services for certain workers adversely affected by the NAFTA who are not eligible for the statutory program. For this program, the Secretary will use existing authority under JTPA Title III to provide assistance (to be referred to as NAFTA-Title III) to workers in secondary firms, that is, firms that supply or assemble products produced by directly affected firms certified under NAFTA- TAA, as well as to provide income support to workers eligible for assistance under NAFTA-TAA who do not meet the requirements for receiving income support payments under that program. Collectively, these provisions are known as the "NAFTA Bridge" program. Title III and NAFTA: Title III funds may be used to provide allowable services to eligible dislocated workers, and to provide rapid response assistance to workers affected by plant closures and substantial layoffs. Under the provisions of the Act and the accompanying Statement of Administrative Action, States are specifically authorized to provide assistance under Title III based on the following circumstances: a. Title III funds are to be used to provide rapid response and basic readjustment services when the Governor has made a preliminary finding that worker dislocation is a result of NAFTA. Briefly, the Governor is responsible for making a preliminary finding, as part of the process described in GAL 7-94 (see Attachment B). Pursuant to Section 250(b)(2)(C) of the Trade Act, as amended by the NAFTA Implementation Act, if the Governor makes an affirmative preliminary finding that the employment of workers at a directly affected firm has been affected by increased imports from or production shifts to Canada or Mexico, the Governor must "ensure that rapid response and basic readjustment services authorized under other Federal law are made available to the workers." This statutory directive has the effect of establishing Title III eligibility for rapid response and basic readjustment services for individuals in a worker group for which the Governor has made an affirmative preliminary finding. b. Title III funds have been committed for use to provide needs-related payments to workers who are covered by a certification under the NAFTA-TAA program but who are not eligible for income support under that component. c. Title III funds have also been committed for use in providing Title III services to workers in firms supplying components to directly affected firms, workers involved in assembly of products made by directly affected firms, and certain other workers. These other workers include family farmers and farm workers who are adversely affected by the NAFTA but do not meet the "group of workers" requirement for filing a petition under the NAFTA-TAA program. In order to ensure comprehensive planning and coordination of the delivery of services to dislocated workers, States are also to ensure the active involvement of the Title III system in providing rapid response assistance and appropriate basic readjustment services for any worker group certified by the Secretary as eligible to apply for assistance under Subchapter A of the Trade Act (i.e., the "regular" TAA program). Effects on Title III Programs: a. Rapid Response. The NAFTA agreements do not modify the basic substance of rapid response assistance or basic readjustment services. States are expected to provide their standard level of rapid response assistance upon becoming aware of a plant closure or substantial layoff regardless of whether the event is subject to a NAFTA petition. For any dislocation event for which the Governor has made an affirmative preliminary finding, States must ensure that appropriate levels of rapid response assistance and basic readjustment services are made available. Pursuant to 20 CFR 631.30(b)(6), the Governor may,under exceptional circumstances, authorize rapid response assistance for layoffs which do not qualify as "substantial" layoffs. "Exceptional circumstances" include those situations in which layoffs would have a major impact upon the community(ies) in which they occur. To carry out this responsibility under Section 250(b)(2)(C) of the Trade Act, the Governor must provide rapid response assistance to a NAFTA-related dislocation event even if it is below the State's threshold for "substantial layoff." Rapid response is an activity whose purposes include the provision of information on available programs and services to workers who have been or are likely to be terminated or laid off, and the assessment of need for additional assistance. States are encouraged to develop and implement appropriate methods of achieving the goals of rapid response in those situations where the number of affected workers is below the threshold and does not require a full-scale, on-site form of rapid response. Such methods should be cost effective and responsive to the workers' needs; they should also be developed with the cooperation of the substate grantees. b. Income Support for Certain NAFTA-TAA Certified Workers. Workers whom the Secretary has certified as eligible to apply for assistance under NAFTA-TAA may,under certain circumstances, be eligible for needs-related payments from the Title III program. Under NAFTA-TAA, workers who are not eligible for unemployment compensation, do not meet the tenure requirement under TAA, or were unable to meet the 16-week/6-week deadline for enrollment in training are not eligible for Trade Readjustment Allowances. The following groups of individuals may receive income support through NAFTA-Title III if they are enrolled in a training program approved under Section 236 of the Trade Act: (1) Workers who are not eligible for unemployment compensation; (2) Workers who do not meet the tenure requirement for employment at the subject firm (26 out of the 52 weeks prior to separation); (3) Workers who were unable to meet the enrollment deadline because the first available enrollment date was past the deadline. (4) Workers who otherwise would have met the deadline but who were unable to meet the enrollment deadline because a course was abruptly canceled. Income support amounts and duration are described in d. Income Support, below. c. Workers in secondary firms whose employment the Secretary has found to be indirectly affected by NAFTA. Workers in secondary firms, that is, firms that supply or assemble products produced by directly affected firms certified under NAFTA-TAA, may receive assistance under the Title III program. Such assistance includes the same activities (rapid response, basic readjustment services, out-of-area job search, relocation allowances, retraining and income support in the form of needs-related payments) as are available to workers in directly affected firms under NAFTA-TAA. So as not to place an undue burden on the affected workers, the process by which workers in secondary firms are identified as eligible to receive assistance under Title III will be, in most cases, the same process used to certify the eligibility of workers in directly affected firms. A petition may be filed for any group of workers believed to be adversely affected by increased imports from or the transfer of production to Canada or Mexico, as described in GAL 7-94. Preliminary fact finding activities will be carried out by the State.Concurrent and subsequent activities required to determine the group's eligibility will be carried out by the Department of Labor, including, as appropriate, a determination of indirect impact. Information regarding the Department's decision on each petition will immediately be sent to the Governor. d. Income Support. Workers in groups described at b. and c. above may receive income support in the form of needs-related payments under the Title III program for weeks that the individual is in training, subject to the following: (1) Enrollment deadline. Payments may be made only if the worker has enrolled in training by the end of the sixteenth week of unemployment or, if later, within six weeks after the Secretary has issued a certification, or if the worker has been granted a limited extension in the enrollment period based on "extenuating circumstances" (described in e., below). (2) Amount and duration of income support. The weekly amount of income support will be the same as the worker's unemployment compensation payment and the maximum duration of such support will be 52 weeks. Workers who do not qualify for unemployment compensation, such as certain farm workers and seasonal workers, will be eligible for income support if they worked at least eight weeks during the previous year. The weekly amount for such workers will be equal to the minimum unemployment compensation benefit level in the State and will be available for a period that equals the number of weeks that the worker was employed in the previous 52 weeks. (3) Source of income support. Income support for workers in groups described at b. and c.above may be paid from funds allotted by formula under Part A of Title III only if the workers meet the eligibility requirements at Section 314(e) of the JTPA. Section 314(e) authorizes the payment of needs-related payments to an individual: who is unemployed and does not qualify or has ceased to qualify for unemployment compensation... To be eligible for such payments, an eligible dislocated worker who has ceased to qualify for unemployment compensation must have been enrolled in training by the end of the 13th week of the worker's initial unemployment compensation benefit period, or, if later, the end of the 8th week after an employee is informed that a short term-layoff will in fact exceed 6 months. Individuals eligible for income support under the NAFTA-Title III program who fail to meet the eligibility criteria described above may receive income support only through funds provided by the Secretary under Part B of Title III. (See 6., Availability of Funds.) e. "Extenuating circumstances". The Trade Act, as amended by the NAFTA Implementation Act, provides that the Secretary, for justifiable cause, may extend the time for enrollment into an approved training program for a period not to exceed 30 days. GAL 7-94 contains additional guidance and background describing application of the "extenuating circumstances" consideration to workers eligible for NAFTA-TAA. States and local grantees implementing the Title III portion of the NAFTA Bridge program are to use these criteria to consider "extenuating circumstances" which delay enrollment in training beyond the deadline for receipt of needs-related payments under Title III. Only those individuals who have been approved for a training program which is scheduled to begin after the deadline, or who have enrolled in an approved training program for which a course was abruptly canceled, may be found eligible to receive needs-related payments if they enroll in training beyond the 16 week/6 week deadline. Availability of Funds: In cases where local resources are insufficient to support State and local responsibilities under the NAFTA-Title III program, and in cases where participants are not eligible for income support using formula funds provided under Part A, funds reserved by the Secretary under Part B of Title III (the "reserve account") are available to support such activities. Until such time as the Department issues procedures for applying for Title III funds to serve individuals eligible for assistance under the NAFTA-Title III program, States may apply for such funds using the procedures issued July 9, 1992 (57 Federal Register 30536). Actions Required: The Governor of each State has designated a State official who is responsible for handling petitions filed under the NAFTA program. (See Attachment C.) It is the mutual responsibility of the Dislocated Worker Unit (DWU) and the designated agency contact for NAFTA-TAA to ensure that a system is in place to coordinate and share information between the two programs. This system must include a provision that the NAFTA-TAA contact will notify the DWU: a) upon receipt of a petition alleging NAFTA impact; b) when the Governor has made a preliminary finding for such a petition; and c) at the time of receipt of the Secretary's final determination of NAFTA-TAA eligibility. In addition, the DWU should ensure that information about these two programs is provided to workers, labor organizations, firms, and other appropriate organizations as part of its information dissemination activities and during its ongoing operations such as rapid response. The Governor must determine which State agency or unit is responsible for administering the delivery of services under the NAFTA-Title III program. Each State must determine how needs-related payments will be provided to individuals identified as eligible for this program under 5a. and 5b. above. The Department anticipates that most if not all States will identify either the State Employment Security Agency or the Substate Grantees as the provider of income support. Relevant agencies within the Department will work with interested States to identify and develop appropriate arrangements and systems for providing needs-related payments through the unemployment compensation system.

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2. Reference. UIPL 28-92 (June 4, 1992). Background: During each of the past four fiscal years the National Office (NO) has provided an increasing number of SESAs with the resources necessary to implement QC Program Improvement (PI) recommendations. The implementation of the PI recommendations has contributed greatly in enhancing the SESAs overall UI operations, covering a wide range of UI activities. Policy: In FY 94 the NO will continue to provide limited funding for SESAs to implement QC/PI recommendations within their UI program. States are invited to submit proposals for additional funds for FY 94. Eligibility is open to all States that have documented problems identified through QC findings that need to be corrected to improve operations. This includes both the Benefits and Revenue QC programs. The SESAs submitting requests for additional funding should describe: problems identified from QC findings; the changes, actions, etc., to be accomplished in the proposed project; the type of personnel that will be involved; and the additional resources in staff and material (e.g., programming and equipment) that will be required, including one-time start-up costs. The proposal must also contain the timeframes for the process including development, training and implementation. In addition, where outside contractor assistance is necessary, the proposal must include an estimate of the level of contractor effort. States should have developed and started the initial implementation phase of the project by October 1, 1994. After one year of operation, SESAs must submit a report describing the implementation effort and the resulting outcomes. This report should be received in the NO by December 16, 1995. The SESA must also agree to periodic Regional Office/National Office monitoring of progress. Funds granted for PI implementation are for the express purpose presented in the agency's proposal as approved, including any clarifications or stipulations made by the Department. By accepting funding for this initiative, States are agreeing to the conditions and timeframes set forth in the proposal. Failure to implement funded proposals, or redirection of any portion of the funds allocated for this purpose, may subject the funding to recapture or audit exception. The SESAs which are unable to initiate PI projects and/or obligate the funds should return those funds to the NO as soon as they become aware of the inability to implement the project, so that other approved projects may be funded. In the event that unforeseen circumstances prevent the State from obligating these funds by December 31, l994, a formal extension request must be submitted to the NO, Office of Quality Control. The extension request should provide a detailed explanation of the circumstances, and should be for a limited time period only. PI Implementation Funding: The total dollar amount to be set aside for this project has not yet been decided. However, the NO will provide funding to those SESAs selected until the amount dedicated to the initiative is exhausted. The NO must obligate the funding by September 30, 1994. Procedures for Submitting and Reviewing Proposals: a. State Agency Procedures. The SESAs wishing to undertake QC/PI implementation projects should submit a comprehensive proposal based on the criteria above. Attachment A provides an outline for proposals. The proposal must be received in the appropriate Regional Office (RO) no later than ninety (90) days from the date of this UIPL. The RO will forward these proposals to the NO within seven (7) calendar days from receipt. b. NO Proposal Review Procedures. Proposals received timely will be evaluated according to the procedure contained in Attachment B. The panel will review each proposal to determine whether the proposal is consistent with the format contained in Attachment A. All applicants will be notified concerning the outcome of this review. Action Required: Proposals are to be sent to the appropriate RO. Upon completion of the PI Implementation Grant, the State should send the final report to the NO. The final report should be received in the NO no later than December 16, 1995. A copy of this report should be sent to the RO. The SESA administrators are requested to provide this information to appropriate staff.

Reference: TEIN 43-93, Capacity Building Challenge Grants. Background: The need for system-wide capacity building has been discussed for years. Both the Title III Amendments of 1988 and the Job Training Partnership Act (JTPA) Amendments of 1992 emphasized the need for better staff training. Sixteen States have established statewide JTPA Training Institutes. The International Association of Personnel in Employment Security administers a professional certification program in three major employment and training disciplines that is open to anyone who is interested. Further, the Clinton Administration's new initiatives in the areas of school-to- work transition, one stop centers and dislocated worker program consolidation will require existing staff to take on new responsibilities and learn new skills. The time is right, therefore, for ETA to implement an integrated, long range capacity building strategy which addresses the common needs of managers and professionals involved with JTPA, Job Service, Dislocated Worker, and other related programs. Strategy Document: Capacity building, for the employment and training system as a whole, means the "expansion of the ability of the employment and training system to deliver high quality services to its customers." The initial focus of this project will be to improve the job skills, knowledge and expertise of the "front line" workers who staff the agencies and programs which make up our employment and training system. The attached paper details ETA's Capacity Building Strategy. This strategy contains the following major themes: -- Extensive consultation with ETA customers: This continuing effort will solicit extensive input from State and local program practitioners, front-line staff, public interest groups (PIG's), recognized experts, clients and employers. The goal is to sharpen our understanding of the technical assistance and training (TAT) needs of the nation's employment and training system. We envision using a combination of focus groups, surveys, and expert panels to accomplish this task. -- Solicitation of new ideas: As described in TEIN No. 43-93, ETA has issued a solicitation for grant applications to States for the development and/or improvement of cross-agency training delivery systems as well as innovative and replicable program models and training products that have broad application throughout the system. Approximately ten grants totalling approximately $1.0 million are planned for PY94. -- Improvement and support of existing TAT capacity: ETA will offer support to local and regional associations, State training institutes and other technical assistance providers who are already engaged in capacity building among their members. Public Interest Groups and other national level ETA grantees will redirect their future activities to support this capacity building project among their constituents. -- Use of an electronic network: Use of electronic communication throughout the employment and training system will be emphasized. A central clearinghouse of information on "best practices" will be set up and linked electronically to program practitioners throughout the country. -- Pilot Projects: ETA will immediately fund three capacity building pilot projects which are already in the planning stages. These are (1) a peer- to-peer technical assistance model, (2) a self-evaluation instrument for local programs, (3) a set of computer based training modules for the recently developed subject specific Technical Assistance Guide's. ETA's Regional Offices will be extensively involved in the development of these three projects. Distribution: The widest possible distribution of this strategy to all segments of the employment and training community is encouraged. Please share the attached document with local and state employment and training agencies, Private Industry Councils, elected officials and others who have an interest in employment and training or human services programs.

Background: Program letters, or the five letter series, are considered temporary directives containing instructions or information of a short-term nature which complement one of the five parts of the ES Manual. Rather than rewrite and reissue expiring program letters which still contain relevant information or instructions, the expiration date is extended. Attached is a listing of program letters with extended expiration dates for the above period.

References: a. Job Training Partnership Act, as amended. b. Interim Final JTPA Regulations, 20 CFR Part 631, published in the Federal Register on December 29, 1992. c. Training and Employment Information Notice No. 22-93, dated November 15, 1993. d. Training and Employment Information Notice No. 27-93, dated January 11, 1994. Background: Pursuant to 20 CFR 631.36 and 631.40, this document provides instructions to the States for JTPA Title III State Plans. Draft planning instructions were transmitted in Training and Employment Information Notice (TEIN) No. 27-93. OMB Approval and Reporting Burden: The Planning Instructions for Title III State Plans have been approved by the Office of Management and Budget (OMB) according to the Paperwork Reduction Act of 1980 under OMB Approval No. 1205-0273 to expire June 30, 1996. Public reporting burden for this collection of information is estimated to average 20 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Office of IRM Policy, Department of Labor, Room N-1301, 200 Constitution Avenue, N.W., Washington, D. C. 20210; and to the Office of Management and Budget, Paperwork Reduction Project (1205-0273), Washington, D. C. 20503. Title III Planning Process for PY 1994 and PY 1995: The draft planning instructions issued under TEIN 27-93 have undergone several minor changes and one major change as a result of comments received and the OMB review process. Attachment A is the draft instructions with redline and strikeout indicating the changes for the final instructions, to aid in locating them. Attachment B is the final instructions reflecting those changes. The major change in the instructions was the deletion of Section III from the draft State plan, which discussed program improvement strategies for PY 1994. A number of commentors asked that this section be taken out of the State plan because the May 1 submittal date would not allow enough time to prepare this information. The program improvement strategies will now be a part of the Technical Assistance and Training (TAT) Initiative. In support of State efforts to improve program quality and capacity, the Department will make available a limited amount of TAT funds to support special TAT projects identified by States and substate grantees to be completed by the end of PY 1994. These projects must address one or more of the program emphases included in the program improvement strategies section of the draft State planning instructions, and must be in addition to ongoing State TAT activities and responsibilities. Procedures for applying for these funds will be described in a forthcoming TEIN. The focus of the planning activities continues to be expanding and improving the quality of services to, and outcomes for, dislocated workers and employers, as discussed in the introduction to the planning instructions. State planning should also consider the implementation of the Worker Profiling and Reemployment Services Initiative authorized under P.L. 103-152 in States during PY 1994 and PY 1995. Under this initiative, UI claimants who are identified as dislocated workers will be required to participate in reemployment services based on a comprehensive Statewide strategy coordinated by the Governor. Depending upon the specific arrangements in each State, these dislocated UI claimants may be referred to EDWAA substate grantees for reemployment services. Specific guidance on the implementation of Worker Profiling and Reemployment Services Systems is provided in FM 35-94, Implementation of a System of Profiling Unemployment Insurance (UI) Claimants and Providing Them with Reemployment Services. Plan Submission: The plans are to be submitted to the Department on or before May 1, 1994. State Title III Plans should be sent to: James D. Van Erden, Administrator, ATTN: Title III Plans, Office of Work-Based Learning, Employment and Training Administration, U.S. Department of Labor, Room N4649, 200 Constitution Avenue, N.W., Washington, D. C. 20210. Each State should also submit a copy of the plan to the appropriate DOL Regional Office. Action: The States should share the final planning instructions with all appropriate parties, including the Dislocated Worker Unit, State Job Training Coordinating Council or State Human Resource Investment Council, and Substate Grantees.

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Agenda: The UIS National Meeting for UI Appeals Management and Support Staff will begin at mid-day on Wednesday, June 8, 1994 and end at mid-day on Friday, June 10, 1994. The Annual Conference of NAUIAB will begin on Monday morning, June 6, 1994 and end at mid-day on Wednesday, June 8, 1994. A copy of each agenda is attached. Participants: The agenda for the National Meeting for UI Appeals Management and Support Staff has been designed for the managers of the lower and higher authority appeals units and the chief appeals clerks and/or appeals support staff supervisors of the lower and higher authority appeals units. The goal is to have an agenda of topics which will provide forums for the management and support staff audiences to exchange their ideas and experiences in managing the high level of appeals workloads that have occurred in recent years. The Annual Conference of NAUIAB will be of interest to unemployment insurance appellate boards and commission members, chief hearing officers responsible for lower authority appellate adjudications, and the chief counsel and chief executive officers of the various higher authority boards and commissions. Meeting Particulars and Inquiries. Travel and per diem costs for State Employment Security Agency (Staff) participants will have to be paid from available State FY 94 allocations: additional funds from ETA are not available for this purpose. Details about the meeting site, costs, and contact persons for additional information are in the attached materials. The Michigan Employment Security Board of Review is hosting the NAUIAB Annual Conference and has graciously agreed to handle the logistics of registration and related matters for the UIS' National Meeting for UI Appeals Management and Support Staff. Action Required: SESA Administrators are requested to provide this information to the appropriate SESA personnel and appellate board members and staff.

Agenda: The UIS National Meeting for UI Appeals Management and Support Staff will begin at mid-day on Wednesday, June 8, 1994 and end at mid-day on Friday, June 10, 1994. The Annual Conference of NAUIAB will begin on Monday morning, June 6, 1994 and end at mid-day on Wednesday, June 8, 1994. A copy of each agenda is attached. Participants: The agenda for the National Meeting for UI Appeals Management and Support Staff has been designed for the managers of the lower and higher authority appeals units and the chief appeals clerks and/or appeals support staff supervisors of the lower and higher authority appeals units. The goal is to have an agenda of topics which will provide forums for the management and support staff audiences to exchange their ideas and experiences in managing the high level of appeals workloads that have occurred in recent years. The Annual Conference of NAUIAB will be of interest to unemployment insurance appellate boards and commission members, chief hearing officers responsible for lower authority appellate adjudications, and the chief counsel and chief executive officers of the various higher authority boards and commissions. Meeting Particulars and Inquiries: Travel and per diem costs for State Employment Security Agency (Staff) participants will have to be paid from available State FY 94 allocations: additional funds from ETA are not available for this purpose. Details about the meeting site, costs, and contact persons for additional information are in the attached materials. The Michigan Employment Security Board of Review is hosting the NAUIAB Annual Conference and has graciously agreed to handle the logistics of registration and related matters for the UIS' National Meeting for UI Appeals Management and Support Staff. Action Required: SESA Administrators are requested to provide this information to the appropriate SESA personnel and appellate board members and staff.

Reference: 20 CFR Part 658.410, 29 CFR Parts 31.5 and 31.7, 20 CFR 653.109, and 29 CFR Part 32.45. Background: As a result of a settlement agreement in the case of NAACP v. Brennan (Civil Action No. 2010-72, U.S.D.C.), the U.S. Department of Labor (DOL) published Federal regulations 20 CFR Parts 651, 653, and 658 onJune 10, 1980. These regulations set forth the role and responsibilities of the United States Employment Service (USES) and State Employment Security Agencies (SESAs) regarding compliance of said regulations. In compliance with 20 CFR 653.109, DOL established recordkeeping requirements to allow for the efficient and effective monitoring of SESAs' regulatory compliance. Pursuant to these recordkeeping requirements, Federal regulations at 20 CFR 658.410 established the State Agency Job Service complaint system and its administrative and processing procedures. ETA Form 8429 was developed for recording complaints filed with the State Employment Service Agencies. The completion of this form is required in order for a complaint to be considered and processed by State agency officials. Further, discrimination complaints (except for handicap complaints) alleging violation(s) of Title VI of the Civil Rights Act, Title IX of the Education Amendments, the Age Discrimination Act, and/or Section 167 of the Job Training Partnership Act, are to be filed with the U.S. Department of Labor, Directorate of Civil Rights. OMB Approval: The reporting requirements for Form ETA 8429 are approved by the Office of Management and Budget (OMB) according to the Paperwork Reduction Act of 1980, under OMB approval No. 1205-0039, to expire June 30, 1996. Action Required: State Administrators are required to provide the above information to appropriate staff.