Part 1: Responsibilities of SCSEP Project Sponsor, Performance Measures and Host Agency Responsibilities

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1 SSAI SCSEP Policy and Procedure Manual Part 1: Responsibilities of SCSEP Project Sponsor, Performance Measures and Host Agency Responsibilities 100 Project Sponsor Criteria and Sponsor Agreement A. Project Sponsor Criteria B. Sponsor Agreement 101 SCSEP Project Sponsor Responsibilities A. Project Direction and Supervision B. Project Sponsors as Host Agencies C. Enrollment from Specific Jurisdictions Can Be Required D. SSAI Performance Measures E. Project Director Training and Executive Conferences F. Other Project Sponsor Responsibilities 102 Review of Community Needs A. Recommendation for Review B. Sources of Community Needs Data C. High Growth Job Training Initiative 103 Community Service Assignments for Participants A. Definition of Community Service Assignment B. Considerations Before Making a Community Service Assignment C. Limitations on Community Service Assignments D. Volunteering at Assigned Host Agencies Prohibited E. Limitations on Host Agencies Providing Services for Fees F. Maintenance of Effort Requirements G. Assignments in SCSEP Project Services H. Community Service Opportunities Listed With Workforce Agency I. Approved Break in Service or Leave of Absence 104 Host Agency Roles and Responsibilities A. Criteria for Host Agencies B. Host Agency Safety and Other Monitoring C. Documentation of Host Agency Safety and Other Monitoring Is Required D. Host Agency Prohibited from Determining Eligibility or Terminating Participants E. Host Agency Prohibited from Paying Participant s Workers Compensation Costs F. Host Agency Orientation and Annual Meetings G. Project Sponsor / Host Agency Agreement H. Required Documents to Include in a Host Agency File 105 Cooperation and Coordination with Other SSAI Subgrantees and Agencies; SCSEP Required Partnerships A. Coordination with Other SSAI Subgrantees B. Cooperative Relationships C. Coordination with Workforce Innovation and Opportunity Act (WIOA) D. Coordination with the State Senior Employment Services Coordination Plan E. Consultation with Area Agency on Aging Part 1 / Page 1 of 1

2 SSAI SCSEP Policy and Procedure Manual Project Sponsor Criteria and Sponsor Agreement A. Project Sponsor Criteria SSAI operates the SCSEP Program exclusively through subgrants to more than 75 local organizations and agencies in 16 states. Its subgrantees (also known as SCSEP project sponsors) include a cross section of local 501(c)(3) non-profit organizations and public agencies that have demonstrated effectiveness in some or all of the following areas: Participation in the public workforce system; Connections to the employer community; Demonstrated effectiveness operating training and employment programs for older workers, including SCSEP; Participation in the aging community and access to low-income seniors; Willingness to make a long-term commitment and investment in SCSEP; and Integration in the local community and its social service networks. Currently, SSAI project sponsors include: Community action agencies and other community-based organizations; Community colleges; Faith-based organizations; Independent Goodwills; Local area agencies on aging; Local government agencies; Local workforce development agencies funded by the Workforce Innovation and Opportunity Act; Rehabilitation organizations serving those with disabilities; and Regional councils of government. B. Sponsor Agreement The Sponsor Agreement is the contract between SSAI and the project sponsor that states the terms and conditions under which the project will be operated. It also includes provisions covering the appropriate administration and accountability of funds and compliance with Title V of the Older Americans Act (OAA), related federal regulations and the procedures outlined in this Manual. (For more information, see Part 9 Reporting and Data Collection, Part 10 SSAI SCSEP Program Finance Procedures, Part 11 Transportation Costs, Auto Liability and Supportive Services and Part 12 SSAI Program Compliance Monitoring, Fiscal Monitoring and Audit.) April / Page 1 of 1

3 SSAI SCSEP Policy and Procedure Manual SCSEP Project Sponsor Responsibilities A. Project Direction and Supervision Among their responsibilities, project sponsors must recruit SCSEP-eligible individuals, assist them in gaining the skills and confidence necessary to secure unsubsidized employment, provide training, especially community service employment for the number of participants specified in the sponsor agreement, facilitate their unsubsidized employment and promote their retention in those jobs. To accomplish this, project sponsors must take the following steps: Employ a project director and other personnel necessary for the direction, programmatic and financial administration and supervision of the SCSEP program (project sponsors must provide SSAI with a copy of the project director s résumé at the time of appointment); Recruit and select eligible participants for enrollment in SCSEP; Select host agencies; Promote linkages and partnerships with local employers and public workforce providers; and Comply with SCSEP policies, procedures and related requirements, such as using SSAI s Webtools and forms to inform SSAI about performance measure data and other information necessary for the program; Make every effort to meet all performance goals outlined in their Sponsor Agreement using both the Payroll-by-Payroll Webtool and the Project Performance Plan Webtool (see section1005-b Webtool for Project Director to Monitor Wage and Fringe Benefit Expense and 1005-C Webtool for Monitoring Costs and Budget.) SSAI also may ask project sponsors to assist in the development of the State Plan and, at times, to represent the interests of SSAI s SCSEP (for more information, see section 106-D Coordination with the State Senior Employment Services Coordination Plan). SSAI requires each sponsor to have a project director who has overall project management for its SCSEP operations and who serves as the primary point of contact with SSAI. In addition to achieving the performance and spending goals specified in their contract, SSAI requires that any sponsor provide a parttime project director for every 30 modified authorized positions and a full-time project director for every 60 modified authorized positions. If the project is required to serve more than 60 modified authorized positions, staff patterns should evolve in conjunction with increases in modified authorized positions minimally for every increment of 30 modified authorized positions above 60. For example, if a sponsor has 90 modified authorized positions, a strong staffing pattern would be a full-time project director and a part-time project assistant; or if a sponsor has 120 modified authorized positions, the sponsor would have either a full-time project director and a full-time assistant or a full-time project director and two part-time assistants. Use of participant staff should be considered in addition to or as additional help beyond the staffing requirements above. The project must request authorization from SSAI in writing for staffing that is less than outlined above. In reviewing a waiver request, SSAI will consider the following factors including but not limited to whether or not the project is achieving its performance goals, is on a Continuous Improvement Plan (CIP), has strong annual programmatic and fiscal reviews, is timely in submitting required reports, and has a credible staffing plan. SSAI may request the removal of a project director for cause. June / Page 1 of 5

4 101 SSAI SCSEP Policy and Procedure Manual B. Project Sponsors as Host Agencies Project sponsors may serve as host agencies and use participants to perform certain SCSEP project services, such as conducting unsubsidized placement follow-up and filling out paperwork, as part of their community service assignments. Sponsors may also assign participants to other programs not related to SCSEP. These assignments must assist participants gain the skills and competencies set forward in their Individual Employment Plans (for more information, see section 301 Assessments, Re-Assessments and Individual Employment Plan). C. Enrollment from Specific Jurisdictions Can Be Required Project sponsors serving more than one jurisdiction for example, more than one county or incorporated city may be required to enroll specific numbers of participants from each county or incorporated city as appropriate to comply with SCSEP s equitable distribution requirements as set by the Department of Labor. Equitable distribution is based on the participant s jurisdiction: for example, county or incorporated city of residence. Project sponsors can find their equitable distribution allocations in Attachment 1 of their Sponsor Agreement. D. SSAI Performance Measures SSAI requires project sponsors to meet all SCSEP performance measures mandated by the Older Americans Act and specified in their sponsor agreement. The first six of the following eleven (11) performance measures are defined by the U.S. Department of Labor (DOL) as core indicators which make them subject to goal setting by DOL. The next three of the following performance measures are defined by the DOL as additional indicators and they are not subject to goal setting and corrective action. The final two performance measures are required by SSAI. SSAI will determine which performance measures are subject to a continuous improvement plan (CIP). SSAI requires sponsors to meet all performance measures as specified in their Sponsor Agreement. The six core indicators for performance are the following: Service Level (the number of eligible individuals served) As outlined in the sponsor agreement, SSAI requires each project sponsor to provide community service employment for a specified number of participants during the program year. The service-level performance measure is defined as the number of participants the project sponsor has served during an entire program year from July 1 June 30 divided by the sponsor s number of modified authorized positions. Modified authorized positions are adjustments in differences in minimum wage among states and areas (for more information about modified authorized positions, see the definition of Modified Authorized Positions in the Glossary). SSAI specifies the annual service level goal in the Sponsor Agreement. Community Service Hours An important purpose of SCSEP is the benefit provided to the project sponsor s local area through the work participants conduct at their community service assignments. SSAI specifies the annual community service hours goal in the Sponsor Agreement and this goal is defined as the total number of community service hours worked by all participants (meaning, the total number of SCSEP hours for which all participants were compensated minus any paid training hours) divided by the number of hours of community service funded by the grant the sponsor received. Project sponsors report the data for the community service hours performance measure in SPARQ via the Community Services Hours function in the WDCS portion of SPARQ. 101 / Page 2 of 5 June 2016

5 SSAI SCSEP Policy and Procedure Manual 101 Service to Most-in-Need (MIN) SSAI requires, to the extent feasible, each project sponsor give priority enrollment to individuals with one or more of the following barriers to employment (see section 201-C for additional information): 1. First Priority: Are veterans or qualified spouses of veterans, regardless of age or any other MIN factor (see section 201-A Priority Must Be Given to Veterans): THEN 2. Have a disability; 3. Live in a rural area; 4. Have low employment prospects; 5. Have failed to find employment through the American Job Center/One-Stop Delivery System; 6. Are homeless or at risk of becoming homeless; 7. Have limited English proficiency; 8. Have low literacy skills; 9. Have a severe disability; 10. Are frail; 11. Are age 75 or older; 12. Are old enough for Social Security retirement but is not receiving it; and/or 13. Have severely limited employment prospects in an area of persistent unemployment. The first six characteristics listed (1-6) are assessed at the time of enrollment and may not be changed after enrollment is completed. Unlike characteristics 1-6, you may update the bolded characteristics (numbered 7 through 13) at any point during the participant s SCSEP participation. In fact, to secure full credit for the MIN performance measure, subgrantees must reconfirm the bolded MIN characteristics (numbered 7 through 13) once per program year, and SSAI requires its subgrantees to reconfirm participant MIN characteristics each July (for more information, see section 201-C Most-in-Need Individuals Are A Service Priority ). MIN characteristics are captured on the SCSEP Participant Form and entered into SPARQ. Measurement of service to those most in need is calculated by totaling the number of most-inneed characteristics (listed above) per participant for all participants served during a program year and dividing that total by the number of all participants served during the same program year (for more information, see section 201 Enrollment Priorities). SSAI specifies the annual most-in-need goal in the Sponsor Agreement. Entry into Unsubsidized Employment As outlined in the Sponsor Agreement, SSAI requires each sponsor to meet or exceed the SCSEP performance indicator for the rate at which participants enter unsubsidized employment during the program year (meaning, placing a participant in full- or part-time paid employment in the public or private sector for at least 1 hour in the first quarter after the quarter in which the participant exits). The entered employment rate is calculated as follows: of those who are not employed at the date of participation: the number of participants who are employed in the first quarter after the exit quarter divided by the number of adult participants who exit during the quarter. Project sponsors must conduct required follow-ups and report the data for the Entered Employment performance measure on the SCSEP Unsubsidized Exit Form and in SPARQ. SSAI specifies the annual entered employment goal in the Sponsor Agreement. June / Page 3 of 5

6 101 SSAI SCSEP Policy and Procedure Manual Retention Rate In Unsubsidized Employment for Six Months The retention rate is defined as, of those who are employed in the first quarter after the exit quarter: the number of participants who are employed in both the second and third quarters after the exit quarter divided by the number of adult participants who exit during the quarter. Project sponsors must conduct required follow-ups and report the data for the retention performance measure on the SCSEP Unsubsidized Exit Form and in SPARQ. SSAI specifies the annual retention goal in the Sponsor Agreement. Average earnings The average earnings measure only looks at those individuals who are included in the retention measure and is defined as, of those participants who are employed in the first, second and third quarters after the exit quarter: the total earnings in the second quarter plus the total earnings in the third quarter after exit divided by the number of participants who exit during the quarter. Project sponsors must conduct required follow-ups and report the data for the average earnings performance measure on the SCSEP Unsubsidized Exit Form and in SPARQ. SSAI specifies the annual average earnings goal in the Sponsor Agreement. The three additional indicators of SCSEP performance as designated by Secretary of Labor are the: Satisfaction of Employers, Participants and Host Agency Supervisors This additional performance measure uses the American Customer Satisfaction Index to determine how satisfied employers, participants and host agency supervisors are with SCSEP. Under SSAI s direction, project sponsors will deliver the satisfaction surveys to selected employers (see section 900 E-3 for more information). The Department of Labor (DOL) will deliver the customer satisfaction surveys to selected participants and host agency supervisors. Project directors must make participants and host agencies aware they may be surveyed by the DOL. Retention in Unsubsidized Employment for One Year This additional performance indicator is defined as, of those who are employed in the first quarter after the exit quarter: the number of participants who are employed in the fourth quarter after the exit quarter divided by the number of participants who exit during the quarter. Project sponsors must conduct required follow-ups report the data for this performance measure on the SCSEP Unsubsidized Exit Form and in SPARQ. Volunteer Work Indicator This purpose of this additional indicator is to determine whether participation on SCSEP contributes to a participant volunteering. This formula for this measure is: of those participants not engaged in volunteer work at the time of entry into the SCSEP, the number of such participants who perform volunteer work in the first quarter after the exit quarter, divided by the number of such participants who exit during the quarter. Project sponsors capture the data for this indicator on the SCSEP Participant Form, SCSEP Community Service Form, and the SCSEP Exit Forms and report the data in SPARQ. The final two (2) performance measures, which are required by SSAI, are the following: Unsubsidized placement This goal is a percentage set annually by SSAI and is calculated by dividing the number of participants who exit into unsubsidized positions during a program year from July 1 to June 30 by the number of modified authorized positions of the project sponsor. SSAI specifies the unsubsidized placement goal annually in the Sponsor Agreement. Spend 100% of Participant Wage and Fringe Benefits funding in the sponsor s subgrant by the end of each program year. 101 / Page 4 of 5 June 2016

7 SSAI SCSEP Policy and Procedure Manual 101 E. Project Director Training and Executive Conferences SSAI trains and provides technical assistance to its sponsors in several ways, including but not limited to: A New Project Director Training conference; Onsite training and technical assistance to new and tenured project directors; Sponsor meetings by state to promote cooperation and mutual support among all SSAI subgrantees within a state, share best practices and innovations to strengthen statewide performance, and build coordination with state SCSEP directors; Additional training on specific topics via webinar, Skype, online or conference call; and Peer-to-peer training, exchanges of ideas and onsite visits by project staff. F. Other Project Sponsor Responsibilities Other project sponsor responsibilities include, but are not limited to: Conducting routine participant and host agency meetings; Orienting and assessing participants; Developing and updating individual employment plans; Providing participants appropriate training and supportive services; Ensuring the safe work environment of participants; Conducting required follow-ups on participants who exited into unsubsidized employment; Maintaining eligibility and financial records and accounts; Conducting a periodic review of community and employer needs to identify potential host agencies and developing a wide variety of community service opportunities (for more information, see section 102 Review of Community Needs); Developing community awareness and support for the project; Coordinating and collaborating with local public workforce providers (for example, workforce investment boards, American Job Centers, community colleges, etc.); Promoting SCSEP with area employers; Assisting in coordination efforts, under the direction of SSAI or on behalf of SSAI, to develop the State Senior Employment Services Coordination Plan, which includes participating in the equitable distribution process; Collecting, reporting and using SCSEP-related data; Appointing and using the services of an advisory council, if deemed necessary; Develop and provide to SSAI upon request a written plan for both Disaster Response and Recovery so that the subgrantee may continue to operate and provide SCSEP services under emergency circumstances; and If you cease to administer SCSEP, you must turn over to us complete data files, both electronic format and hard copy when requested. June / Page 5 of 5

8 SSAI SCSEP Policy and Procedure Manual Review of Community Needs A. Recommendation for Review To ensure SCSEP is made available to the greatest number of eligible individuals, it is helpful for project sponsors to conduct periodic reviews of community needs. Such reviews help project sponsors to identify potential host agencies and develop a greater variety of community service assignments for participants. B. Sources of Community Needs Data Project sponsors can review their State Senior Employment Services Coordination Plan to find community needs data. The plan requires states to identify the community services that are most needed and the areas in which they are most in need. (For more information, see section 106-D Cooperation with the State Senior Employment Services Coordination Plan.) Other sources of community needs data include the local Area Agency on Aging, state and local social services departments, planning agencies, councils of governments and state and local employment security agencies, United Way agencies, American Red Cross chapters, chambers of commerce, private foundations, faith-based organizations, central labor councils, Workforce Investment Boards (WIB) and institutions of higher education. C. High-Growth Job Training Initiative The President s High-Growth Job Training Initiative emphasized placing participants into high-growth industries. High-growth industries are those that are projected to add substantial numbers of new jobs to the economy or affect the growth of the other industries, or are existing or emerging businesses being transformed by technology and innovation requiring new skill sets for workers. The 14 high growth industries are the following and when participants exit SCSEP into an unsubsidized job, project staff can note on the SCSEP Unsubsidized Employment Form whether the position obtained by the participant was in a high-growth field. 1. Advanced manufacturing 2. Aerospace 3. Automotive 4. Biotechnology 5. Construction 6. Energy 7. Financial services 8. Geospatial technology 9. Health care 10. Homeland security 11. Hospitality 12. Information technology 13. Retail 14. Transportation April / Page 1 of 1

9 SSAI SCSEP Policy and Procedure Manual Community Service Assignments for Participants A. Definition of Community Service Assignment The Department of Labor considers community service assignment and community service employment assignment to be the same in that they both represent part-time, temporary job training through a work experience that is paid with grant funds at 501(c)(3) nonprofit or governmental organizations. Community service assignments provide participants the opportunity to develop their skills and confidence to meet the goals outlined in their Individual Employment Plan (IEP) such as secure an unsubsidized position, earn their GED, and/or contribute to the general welfare of a community. Participants are assigned to specific community service assignments based on their initial assessment and individual employment plan as well as community needs. Specifically, community service assignments should lead to unsubsidized employment by: (1) emphasizing community services assignments where the participant develops transferable skills in demand by local employers; and (2) combining community service assignments with other permissible training (for example, classroom training, on-the-job training or on-the-job experience in the private forprofit sector) as funding permits, especially for participants that need to overcome extraordinary barriers to unsubsidized employment and would benefit from additional training. These assignments cover a broad spectrum of services from literacy and libraries to services targeted to the elderly to recreational services. For a more complete list, see the SCSEP Community Service Assignment Form, #17, which is available in this manual s Appendix II or on the partners page of SSAI s website at All community service assignments must be attached to a host agency that meets the criteria in section 104 Host Agency Roles and Responsibilities. B. Considerations Before Making a Community Service Assignment Once a participant has been determined eligible in the program, he or she must be given a specific community service assignment before he or she can be paid for assessment, orientation or pre-assignment training. Before placing a participant into a community service assignment, the project director must: Decide where and in what capacity the participant is likely to gain new skills and self-confidence. This decision should be based on information obtained during the initial interview and through completion of the SCSEP Participant Form. Project directors also should take into account the participant s preferences, Individual Employment Plan employment goals, skills, any training he or she may have received and local host agency and other employer needs. Confer with each host agency supervisor to determine the specific assignment duties, the skills to be attained, the training and supervision to ensure the skills are attained, the days and hours of community service, any pre-assignment training, if applicable, as well as to develop a current written assignment description. June / Page 1 of 4

10 103 SSAI SCSEP Policy and Procedure Manual Conduct a host agency safety consultation about the work environment and training responsibilities for each participant, and document this consultation on the Host Agency Health and Safety Consultation Checklist available in this manual s Appendix II and on the partners page of SSAI s website at (For more information, see section 300-B Receipt of Copy of Personnel Policy and Orientation Acknowledged.) Ensure that each host agency supervisor understands the policies, procedures and goals of the sponsor s project. To the greatest extent possible, ensure that each participant is assigned to a host agency in or near the community in which he or she resides. Keep in mind that after a participant is enrolled in other words, after the individual has been found eligible, has been given a community service assignment, and is receiving a service he or she must be paid wages for time spent in orientation, training, assessment or in receiving any other service. This requirement applies even if the participant has yet to start his or her assigned community service assignment at the host agency. (For more information, see section 700 Hours of Community Service and Participant Wages.) C. Limitations on Community Service Assignments Participants must not be assigned to community service assignments that: Involve the construction, operation or maintenance of any facility used or to be used as a place of sectarian religious instruction or worship, including but not limited to assignments in classrooms, lunchrooms, offices and maintenance departments. (Community service programs that operate in religious facilities are exempt provided their function does not involve religious instruction or worship); Primarily benefit private, profit-making organizations (For more information, see section 401-C Types of Allowable Training); Are entrepreneurial in nature and revenue generating (For example, which consign crafts or other goods for public sale); Directly or indirectly benefit any private or personal undertaking of any project sponsor or host agency staff member; and Involve a political party. In addition, sponsors can rotate participants to different host agency assignments according to their Individual Employment Plans. (For more information, see section 800 Change of Community Service Assignment Policy.) Finally, assignments must not reduce employment opportunities or vacancies available to people not in SCSEP; must not displace current employees or reduce their hours of non-overtime work, wages, or employment benefits; must not impair existing contracts or result in federal funds being substituted for other funds to pay for work; and must not employ participants to do the work of someone who has been laid off. (For more information, see section 103-F Maintenance of Effort Requirements.) D. Volunteering at Assigned Host Agencies Prohibited Participants are prohibited from volunteering at the host agencies to which they are assigned. 103 / Page 2 of 4 June 2015

11 SSAI SCSEP Policy and Procedure Manual 103 E. Limitations on Host Agencies Providing Services for Fees Organizations that provide services and charge client or service fees may be eligible to serve as host agencies provided that those fees are used to underwrite the delivery of services to economically disadvantaged people and the value of the community service exceeds the fees. For example, participants may be assigned to commodity food distribution centers, food banks, home health care programs, nonprofit adult and child care programs, sheltered workshops, Goodwill Industries and Salvation Army Centers. F. Maintenance of Effort Requirements Project directors should ensure that participants are assigned to community service assignments at host agencies that otherwise are not funded. Community service assignments for participants should: Result in an increase in employment opportunities in addition to those which otherwise would be available; Not result in the displacement of currently employed workers, including such partial displacement as reduction in hours of non-overtime work, wages or employment benefits; Not impair any existing contract for service, or result in the substitution of federal funds provided for the operation of the sponsor s project for other funds in connection with work that otherwise would be performed; Not substitute any community service assignment funded by the project sponsor for any existing federally assisted job; and Not be in place of a position that is the same as or substantially the same as one that is occupied by any other person who is on layoff unless the layoff or reduction in force that led to the vacancy has existed for at least 24 months. If a sponsor discovers a violation of maintenance of effort, it must immediately send a letter to the host agency executive director specifying the charge and providing an opportunity to respond. If, after investigation, the subgrantee determines a violation has occurred, it must reassign all participants and terminate the host agency contract. With SSAI approval, the sponsor can reinstate a host agency if sufficient corrective actions are taken. G. Assignments in SCSEP Project Services Project directors are encouraged to assign participants to SCSEP project services; however, such assignments should be consistent with the participant s unsubsidized employment objectives and Individual Employment Plan. Participants assigned to such duties are subject to the provisions of the durational limit. (For detailed information, see section 203-D Durational Limit on Individual s Program Participation, and 700-B Limitations on Hours of Community Service.) Some examples of project services are the following: Host agency monitoring; Gathering information for eligibility and the SCSEP Participant Form; Gathering information or conducting unsubsidized placement follow-up services/activities for other participants; Providing job development; Serving as an employment coach for other participants; Entering program data into SPARQ; Serving as a recruiter for other participants; and Providing general administrative assistance to the project director. June / Page 3 of 4

12 103 SSAI SCSEP Policy and Procedure Manual H. Community Service Opportunities Listed With Workforce Agency Project sponsors should list all community service opportunities with the State s American Job Centers and all appropriate offices and must use the American Job Center delivery service in the recruitment and selection of eligible individuals. I. Approved Break in Service or Leave of Absence Participants must always be assigned to a community service assignment. An approved break of service is used when you intend to transfer the participant to another host agency and you have not yet identified the new host agency and the process takes more than three consecutive work days. An approved break also applies to participants who do not earn wages for more than three consecutive days at their current community service assignment. You only need to report an approved break of more than three consecutive days. Several possible reasons for the approved break in service: medical or family health, personal / leave of absence without pay, and administrative. (For more information, see section 700-D Approved Break in Participation / Leave Without Pay.) All approved breaks in service / approved leaves of absence of longer than three days must be entered into the participant s record in SPARQ. If a participant requests a leave of absence of more than three (3) consecutive work days permissible under your participant policies and procedures do not remove them from active participation; simply leave them connected to their current assignment and record the fact in SPARQ to stop the participant s 48-month durational limit clock. 103 / Page 4 of 4 June 2015

13 SSAI SCSEP Policy and Procedure Manual Host Agency Roles and Responsibilities A. Criteria for Host Agencies Project directors are responsible for assigning each participant to an appropriate community service assignment in a host agency that will lead to unsubsidized employment. A host agency must: Be a non-partisan, non-profit or governmental organization. Organizations eligible to act as host agencies are public agencies operated by non-profit agencies or units of government with certification under Section 501(c)(3) of the U.S. Internal Revenue Code. Prior to serving as a host agency, organizations must submit their Federal Employer Identification Number (FEIN) and Section 501(c)(3) designations. Because Section 508 of the U.S. Internal Revenue Service Code states that churches are taxexempt and do not need to apply for 501(c)(3) status, churches can be host agencies even if they do not have a 501(c)(3) IRS determination. However, project sponsors can only assign SCSEP participants to churches if the community service assignment does not involve any religious activities (see policy 103-C for Limitations on Community Service Assignments). Allow participants to learn and use skills and competencies valued by local employers, especially those in high-growth industries and help participants obtain unsubsidized employment. Provide adequate orientation, instruction and training for the participant s assignment along with a proper work environment. Provide suitable supervision to enable each participant to perform as a productive and effective worker and gain the skills outlined in the participant s Individual Employment Plan (IEP) and training agreement. Establish assignments that support the goals of SCSEP as well as the participant s goals established in the IEP. The host agency also must be willing to work with the project director to develop the participant s IEP and performance evaluation. B. Host Agency Safety and Other Monitoring SCSEP project directors are responsible for obtaining reasonable assurances from the host agency that the participants working conditions are safe and healthful, which will be documented in the host agency agreement. Participants must not be required or permitted to perform their community service assignments in buildings or surroundings or under conditions that are unsanitary or potentially hazardous to their health and safety. 1. Monitoring Requirements SCSEP project directors are to conduct one host agency safety and other monitoring per participant per community service assignment and, thereafter, on an annual basis if the participant stays in the same community service assignment. The first host agency safety and other monitoring review must be completed on or after the assignment date (i.e. #43 Date of Eligibility Determination on the SCSEP Participant Form) and be completed no later than 60 days after the participant started their community service. The host agency safety and other monitoring should be tailored to the individual participant and should be given when the participant is being assigned. Sponsors must record the date of each safety consultation with a participant on-site at his or her host agency and input this date into SPARQ on the SCSEP Community Service Assignment Form (question #16c). June / Page 1 of 4

14 104 SSAI Senior AIDES Program Policy and Procedure Manual 2. Content of Monitoring At the host agency safety and other monitoring visit, the project director should: 1. Interview the participant to determine whether he or she: Is knowledgeable about the duties in the written community service assignment description and training plan; Is satisfied with the assignment and the level of supervision; Has suggestions for changes, improvements or additional training; Has updates for the Individual Employment Plan; Understands the limit on the length of the assignment, payroll procedures and required benefits; and Is making efforts to obtain unsubsidized employment. 2. Interview the host agency supervisor to: Discuss the possibility of hiring the participant; Determine whether he or she has suggestions for changes in the community service assignment description, including the possibility of placing the participant in an assignment with more responsibility or providing training that will make the participant more employable; Ensure that he or she understands the limit on the length of the participant s current assignment and durational limit (for more information, see section 700-B Limitations on Hours of Community Service Assignment and 203-D Durational Limit on Individual s Program Participation); Ensure compliance with maintenance of effort and other requirements as indicated in the agreement; Determine whether he or she is satisfied with the work being performed by the participant and progress in his/her training; and Determine whether the host agency has received a Customer Satisfaction Survey (for more information, see section 900-E Customer Satisfaction Survey Process). 3. Review the assignment description and training plan to determine: That the participant s duties are the same as those described in the assignment description; That the scheduled hours of community service as set forth in the assignment description and approved by the project sponsor are being followed; That the participant acquiring the skills and confidence outlined in the training plan and Individual Employment Plan; and 4. Ensure that the host agency has proper controls to confirm that participants work the hours claimed on their time sheets, including the signatures of both the host agency supervisor and participant. 104 / Page 2 of 4 June 2016

15 SSAI SCSEP Policy and Procedure Manual 104 C. Documentation of Host Agency Safety and Other Monitoring Is Required Documentation of the host agency safety and other monitoring must be maintained at the local level and the date of the monitoring must be entered into SPARQ. Project directors can use the SSAI Health and Safety Checklist Form as well as a sample Host Agency Monitoring Form found in this manual s Appendix II to document. Project directors must also report the date of consultation in SPARQ. D. Host Agency Prohibited from Determining Eligibility or Terminating Participants Host agencies cannot be responsible for determining the eligibility of an applicant or a current participant, except when the project sponsor is also the host agency. Also, host agencies cannot terminate a participant or sign a SCSEP Exit Form, except when the project sponsor is the host agency. (For more information, see section 602-C Participants and Host Agencies Prohibited from Exiting Participants.) E. Host Agency Prohibited from Paying Participant s Workers Compensation Costs Host agencies are not allowed to pay Workers Compensations Costs for participants. Workers Compensation is a fringe benefit provided by the subgrantee. (For more information, see section 702-A Required Fringe Benefits for Participants). F. Host Agency Orientation and Annual Meetings Project sponsors are required to hold mandatory orientation sessions and annual meetings for host agencies to outline the goals and objectives of SCSEP and the sponsoring organization. At these meetings, sponsors and host agencies will take the following steps: Review the host agencies responsibilities, including maintenance of effort requirements; Discuss participants rights and responsibilities; Discuss what jobs and skills are in demand by local employers that might be attainable by SCSEP participants; Discuss role of host agency supervisors and effective training and supervision methods; Identify computer-related and other training opportunities available at the host agency; and Review other related issues (for example, assessments and Individual Employment Plans, workplace safety). These meetings also are a good opportunity for project sponsors to promote connections with public workforce providers and employers as well as make host agencies aware that they may receive a Customer Satisfaction Survey from the U.S. Department of Labor. (For more information, see section 900-D Customer Satisfaction Survey Process.) G. Project Sponsor / Host Agency Agreement Each host agency must sign an agreement with the SSAI SCSEP project sponsor before any participants can be assigned to community service at the host agency. The agreement must be for one project year, or the appropriate portion thereof, and must be renewed each project year. June / Page 3 of 4

16 104 SSAI Senior AIDES Program Policy and Procedure Manual Project sponsors must ensure that host agency agreements stipulate that participants may not engage in defined lobbying activities, such as making phone calls, sending letters to Congress or assisting others in those activities. Sponsors must also monitor assignments to make sure that the restrictions are being enforced. Project sponsors must maintain records of all current Project Sponsor / Host Agency Agreements, as well as all section 501(c)(3) designations and documentation of Federal Employer Identification Numbers, to ensure that each participant s community service assignment is covered by a current agreement. H. Required Documents to Include in a Host Agency File Each host agency file must consist of at least the following documents: Current Project Sponsor Host Agency Agreement; 501(c)(3) determination letter from the IRS (for non-profit host agencies); and Documentation of the Federal Employer Identification Number (typically found on the Current Project Sponsor Host Agency Agreement). In addition, the following documents, if not filed in the appropriate participant file, should be part of the host agency file: Completed copies of host agency-monitoring documentation; Completed host agency safety checklists (for each participant who has served in a community service assignment at that agency); and Copies of each participant s community service assignment description. 104 / Page 4 of 4 June 2016

17 SSAI SCSEP Policy and Procedure Manual Cooperation and Coordination with Other SSAI Subgrantees and Agencies; SCSEP Required Partnerships A. Coordination with Other SSAI Subgrantees Each SSAI sponsor must coordinate with other SSAI sponsors within its state. The Department of Labor establishes state SCSEP performance goals and budgets on a state-by-state basis. As a consequence, SSAI manages its SCSEP program at the national, state and individual subgrantee levels. While SSAI contracts with each subgrantee individually, it manages performance and budgets at multiple levels and will regularly convene state meetings (typically by conference call) to assure strong state performance. SSAI tracks and shares with every subgrantee in a state both the state s and subgrantees performance. (For more information, see section 901-D.) B. Cooperative Relationships Each SCSEP project sponsor must establish, to the extent feasible, cooperative relationships with other employment and training programs, including those with activities conducted under the Workforce Innovation and Opportunity Act of 2014 (WIOA), American Job Centers and other public workforce providers, and with agencies concerned with seniors. Under direction from SSAI, project sponsors may participate in the planning and development of the State Senior Employment Services Coordination Plan. Project sponsors should form cooperative relationships with these objectives: Selecting community service employment occupational categories, community service assignments and host agencies; Providing a variety of supportive services and training opportunities for participants; Providing a variety of services that respond to the total needs of the community; Providing job search information and other unsubsidized employment assistance; and Achieving equitable distribution of SCSEP positions in the state. C. Coordination with Workforce Innovation and Opportunity Act (WIOA) SCSEP is a required partner under the Workforce Innovation and Opportunity Act (WIOA); therefore, each SSAI project sponsor is also a WIOA partner under the terms outlined in the sponsor agreement. To ensure this coordination, project sponsors are required to: Enter into a MOU with the local Workforce Investment Board, relating to the operation of the One- Stop system; Provide access to SCSEP activities either through at least one physical center in each local area; the American Job Center/One Stop Delivery system; Use a portion of funds available for the program and activities to maintain the one-stop system, including infrastructure costs of the One-Stop; and June / Page 1 of 4

18 105 SSAI Senior AIDES Program Policy and Procedure Manual Must participate in the operation of the American Job Center/One-Stop System by: o Notifying the appropriate American Job Center/One-Stop of the establishment or continuation of an SSAI project. Project sponsors should establish a working relationship with WIOA to: Provide both eligible and ineligible individuals with access to other activities and programs carried out by the American Job Center/One-Stop and other public workforce system partners; Receive referrals from the American Job Center Delivery system for potential SCSEP participants; List all current participants as active job applicants with the American Job Center delivery system or employment services; Increase training and unsubsidized placement opportunities for participants; List the number of modified authorized positions or potential SCSEP opportunities with the American Job Center delivery system; Share and use the SSAI project sponsor or WIOA participant assessments and Individual Employment Plans; Provide SSAI project sponsor publications and materials; Coordinate with other national and state SCSEP grantees when multiple grantees provide services in the local workforce investment area; and Assess such reports/records as unemployment insurance or case management notes to provide required follow-up services or data collection for participants placed into unsubsidized employment. A sample MOU is available in this manual s Appendix II and on the partners page of SSAI s website at D. Coordination with the State Senior Employment Services Coordination Plan The Older Americans Act (OAA) requires the governor of each state, to be eligible for grant funding, to submit to the U.S. Department of Labor a state plan that describes the planning and implementation process of all SCSEP services. In developing the state plan, the governor or designee must obtain advice and recommendations from targeted organizations, including each grantee operating a SCSEP project in the state. The State Plan outlines a four year strategy and must include information on: Long-term strategy for achieving an equitable distribution of SCSEP positions within the State; Long-term strategy for avoiding disruptions to the program when new Census or other reliable data become available, or when there is over-enrollment for any other reason; Long-term strategy for serving minority older individuals under SCSEP; 105 / Page 2 of 4 June 2015

19 SSAI SCSEP Policy and Procedure Manual 105 Long-term projections for job growth in industries and occupations in the State that may provide employment opportunities for older workers, and how those relate to the types of unsubsidized jobs for which SCSEP participants will be trained, and the types of skill training to be provided; Long-term strategy for engaging employers to develop and promote opportunities for the placement of SCSEP participants in unsubsidized employment; Strategy for continuous improvement in the level of performance for entry into unsubsidized employment, and to achieve, at a minimum, the levels specified in 513(a)(2)(E)(ii) of the OAA; Planned actions to coordinate activities of SCSEP grantees with the activities being carried out in the State under Title I of WIOA, including plans for using the WIOA American Job Center delivery system and its partners; Planned actions to coordinate activities of SCSEP grantees with the activities being carried out in the State under other titles of the OAA; Planned actions to coordinate the SCSEP with other public and private entities and programs that provide services to older Americans, such as community and faith-based organizations, transportation programs, and programs for those with special needs or disabilities; Planned actions to coordinate the SCSEP with other labor market and job training initiatives; and Long-term strategy to improve SCSEP services, including planned longer-term changes to the design of the program within the State, and planned changes in the use of SCSEP grantees and program operators to better achieve the goals of the program; this may include recommendations to the Department, as appropriate. The state plan also must include the following information: The ratio of eligible individuals in each service area to the state s total eligible population; The relative distribution of SCSEP-eligible individuals residing in urban and rural areas who have the greatest economic need, are minorities, have limited English proficiency and have the greatest social need; The current and projected employment opportunities in the state by occupation and the types of skills possessed by eligible individuals; The localities and populations for which projects of the type authorized by Title V of the Older Americans Act (OAA) are most needed; Actions taken or planned to coordinate SCSEP activities with activities under Title I of Workforce Innovation and Opportunity Act (WIOA); A description of the process used to obtain advice and recommendations on the State Plan and on steps to coordinate SCSEP services with activities funded under Title I of WIOA; A description of the state s procedures and time line for ensuring an open and inclusive planning process with public comment; June / Page 3 of 4

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