U.S. DEPARTMENT OF LABOR
Employment and Training Administration
Washington, D. C. 20210
April 12, 1996
TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 05-95
ALL STATE JTPA LIAISONS
BARBARA ANN FARMER
Program Guidance and Allocations for the Calendar Year 1996 Summer Youth Employment and Training Program (SYETP)
Purpose. To provide States with program guidance and allocations for the Calendar Year (CY) 1996 Summer Youth Employment and Training Program (SYETP).
The Job Training Partnership Act (JTPA), as amended;
JTPA Final Rules, as published in the Federal Register on September 2, 1994;
Training and Employment Guidance Letter No. 4-95 (February 21, 1996): "Instructions for Submission of State Plans under Title II and Title III of the Job Training Partnership Act for Program Year (PYs) 1996 and 1997; and PY 1996 Wagner-Peyser Act Program Planning Guidance".
Training and Employment Information Notice No. 33-92 (June 1, 1993): "Child Labor Restrictions Applicable to Youth Participants in Job Training Partnership Act (JTPA) Funded Programs".
Training and Employment Information Notice No. 23-95 (April 11, 1996): "Calendar Year 1996 Summer Youth Initiatives".
Summer Jobs Funding Level. The Department of Labor is obligating $625 million to the States for the CY 96 Summer Youth Employment Program (SYETP) under Title II-B of the Job Training Partnership Act (JTPA). (State allocations are contained in Attachment A.) These funds are being obligated as Fiscal Year (FY) 96 funds, not as Program Year 96 funds. Notices of Obligation will be issued under the current PY 95 JTPA grant agreement to obligate these funds to the States, and they will not be combined with Title II-A and Title II-C funds. Thus, States will be required to submit a separate JTPA Title II Quarterly Status Report (JQSR) for these FY 1996 Title II-B funds, and they will not be combined with Title II-A and Title II-C PY 1996 data. Additionally, States will draw cash under the Payment Management System (PMS) for Title II-B FY 1996 funds, and these II-B funds will not be combined with other Title II funds under PMS. A further explanation and reporting instructions are contained in Attachment B.
Program goals. In this year's summer program, the Department maintains its commitment to providing the nation's disadvantaged youth with solid work experiences, which for many youth represent the first step into the labor force. The Department of Labor's vision of the summer program is one where new entrants to the labor force and those with limited job histories:
build and refine a strong foundation of work, employment competencies, and the discipline of work; and,
gain an appreciation of the inextricable connection between work and learning which is critical to a long-term attachment to and success in a rapidly changing labor market.
This message regarding the connection between education and work is consistent with the on-going school-to-work message communicated by the Departments of Labor and Education to States, SDAs, local school systems, employers and youth.
We recognize that we need to help youth acquire the knowledge, skills, abilities, and labor market information they need to make a smooth transition from school to career-oriented work or further education or training.
Program Emphases. This summer's program emphases focus on the need for States and SDAs to:
Maximize the number of economically disadvantaged youth participating in SYETP;
Fully utilize all available funding, including new FY 1996 monies as well as any carryover from previous years, to provide maximum opportunities for participation in SYETP;
Provide meaningful worksites with capable, trained supervisors;
Provide educational enrichment, including life skills training;
Strengthen linkages between SYETP and the year-round youth program under Title II-C and the School-to-Work initiatives; and,
Work with the private sector to provide more unsubsidized employment opportunities for economically disadvantaged youth.
Work Experience. Work experience continues to be one of the most effective components in the summer program. How- ever, when viewed from a system-wide perspective, it is clear that SDAs and worksites can further improve, refine and enhance this component.
All States and SDAs should ensure that worksites introduce and/or reinforce the rigors, demands, rewards, and sanctions associated with holding a job. Prior to starting on the job, participants should clearly understand basic employment rules and requirements and employer expectations, including the necessity to perform well in a structured educational setting as well as on the job. Documented learning experiences should be an integral part of the youth's work experience.
Integration of Work and Learning. Work-based learning and classroom-based learning must complement and reinforce each other so that the youth are provided with assistance in developing and refining attitudes, values, and work habits which will contribute to their success in the workplace. Many SDAs' program designs have traditionally consisted of two distinct components--work experience and classroom education--with very little interaction between the two. However, the two components need to be complementary and mutually-reinforcing. Achieving this connection will require early and continuous interaction between the two components.
Some SDAs have integrated work and learning to the point that all learning is acquired on the job. This is an acceptable model, although program experience suggests that this approach is most useful for older youth who do not suffer from serious educational deficiencies.
On the other hand, some SDAs have a program design which provides an educational services component, but no work experience component, for either all its participants or for a defined segment, e.g., 14- and 15-year olds. ETA strongly recommends that all participants, including 14- and 15-year olds, spend considerable time on an actual job. If an SDA has an education-only program design, the SDA must provide an explanation in the job training plan as to why such a design is the most effective strategy for the youth involved. Even if such a design is approved by the State, to be consistent with SYETP's statutory purpose, such participants must receive some form of work-related experience, such as vocational exploration, job shadowing, simulated workplaces, or other similar activity.
What ETA is again promoting is an approach to the summer program which goes beyond static and self-contained work experience and education components; what we are seeking is a concept of the summer program as a "total learning experience", with relevant learning, including academic instruction and life skills training, taking place in any activity in which a youth participates. Thus, classrooms should be transformed into interactive, work-related environments; and worksites should be re-oriented to include rich learning experiences related to the SCANS Foundation Skills and Competencies.
School-to-Work. The components outlined in the School-to-Work Opportunities Act (STWOA) continue to serve as the framework of the Administration's strategy for meeting the education and job training needs of America's youth. SDAs should work with State and local school-to-work (STW) partnerships in the development and establishment of the STW components, including school-based learning, work-based learning, and connecting activities, as well as skill certification and career major development, so that SYETP effectively coordinates with the goals of each State's school-to-work system.
The STWOA requires State partnerships and encourages local partnerships to include representatives of the State and local job training systems. As in the past two years, the Department encourages JTPA Liaisons and SDAs to take active roles in the implementation of State and local efforts and to coordinate the activities of the SYETP with on-going school-to-work activities.
Effective working relationships between SDAs and the local school systems are crucial to achieving the goals of enriching the quality of the education component and preserving educational gains made during the summer by providing services to youth year-round. States, SDAs, and local school systems should strive to develop productive working relationships with the goal of achieving their mutually shared objective--namely, the preparation of youth-all youth-for a successful work and personal life. It is is essential that SDAs and local school systems maintain open channels of communication and share information, either formally or informally.
Year-Round Services to Youth. Strengthening linkages between SYETP and the year-round youth program under Title II-C remains an ETA goal. The ability to transfer funds between Title II-B and Title II-C clearly facilitates such strengthening of linkages. This enhanced flexibility also has positive implications for the application of School-to-Work principles and practices in the local community.
Months of Operation for SYETP. While section 254 of the Act provides that SYETP can only operate in the "summer months or in an equivalent vacation period where there is a year-round school system", we have broadened this through interpretation in the regulations to be "school vacation periods" and indicated that planning and intake can occur before school ends. The regulations also allow for concurrent enrollment of youth in Title II-B and Title II-C programs. However, there is nothing in the statute that would allow SYETP to begin employing youth before the beginning of the school vacation period. SYETP is envisioned by the statute as an in-school program which is designed to encourage youth to stay in school, either secondary or post-secondary.
Where there are out-of-school youth whom the SDA wishes to serve prior to the school vacation period in its area, the SDA may chose among several different approaches. The SDA can 1) run an employment program for out-of-school youth before the end of the school year under Title II-C, using existing II-C funds or transferred funds from II-A or II-B; 2) develop a program of concurrent enrollment (II-B and II-C); 3) use Wagner-Peyser or locally funded staff to do job development and placement for this group before school ends.
Objective Assessment and Individual Services Strategy (ISS). The requirements of objective assessment have been clearly specified in the JTPA statute (as amended by the Goals 2000: Educate America Act) and the final JTPA regulations. However, ETA will neither require nor recommend any particular assessment device. It is the responsibility of the SDAs to utilize effective assessment instruments. Likewise, while pre- and post-testing of educational attainment is strongly encouraged, but not required, ETA will not recommend any particular testing protocol. SDAs are urged to consult with their local school systems to determine which measurements of educational achievement are most appropriate and useful to both the individual SDAs and the local school system(s). In measuring a participant's workplace skills, ETA recommends that SDAs specifically explore the use of participant portfolios as a measurement device. In addition, there is evidence to suggest that the use of portfolios is also gaining increasing acceptance among school systems for measuring educational attainment, particularly in school-to-work activities.
Limited Private Sector Internships/Entry EmploymentExperience. While the JTPA regulations provide the requirements for this activity, States and SDAs are again reminded that certain vulnerabilities are inherent in this activity. Some examples include:
the occurrence or perception of favoritism shown to one employer over another;
placing economically disadvantaged youth in subsidized jobs that they can obtain on their own.
displacing non-economically disadvantaged youth from jobs that they normally secure in the summer.
Therefore, SDAs should maintain documentation on why particular employers were selected or not selected to serve as worksites.
States and SDAs are also encouraged to operate their internship program in tandem with their voluntary private sector summer jobs campaign so as to assure that these two initiatives complement rather than compete against each other.
Life Skills Training. The majority of SYETP participants need assistance in developing work habits and in refining attitudes, values, and behavior patterns. This assistance should be part of the educational services provided in every summer youth work experience component. Many SDAs term such individual developmental activities "life skills training". Assistance should be focused on those attitudes, values, and behavior patterns which are vital to success in educational pursuits, on the job, and as a citizen.
Many of the SCANS Foundation Skills (e.g.,"Personal Qualities") and Competencies (e.g., "Interpersonal") are geared to individual development. Thus, SDAs are encouraged to incorporate individual development activities into learning on the job and in an educational setting.
When individual development activities are integrated with learning on the job and in an educational setting, they may be properly considered part of an SDA's education component.
However, stand-alone personal development activities, while allowable, are not to be considered part of the education component.
Job Safety and Health. States and SDAs are reminded to review Federal, State and local safety and job health standards and child labor restrictions to ensure that participants are not assigned to job activities which violate the standards and/or restrictions. For specific guidance, States and SDAs may refer to TEIN 33-92: " Child Labor Restrictions Applicable to Youth Participants in Job Training Partnership Act (JTPA) Funded Programs."
Private Sector Summer Jobs Efforts.
Private sector campaigns. All States and SDAs are strongly encouraged to work with local business leaders in strengthening the coordination with the private sector in creating unsubsidized summer job opportunities for economically disadvantaged youth. As stated in section 4 above, one of this year's program emphases is to increase the total number of these jobs identified and filled by disadvantaged youth.
Title II-B funds may be used to support private sector programs which are not limited to just JTPA eligible youth within the following parameters. JTPA funds can be used where States and SDAs are working with local businesses to plan these private sector programs, including planning employer outreach and recruitment campaigns, fundraising, etc., as well as for recruitment, intake, eligibility determination for community-wide summer jobs programs that serve JTPA eligible and non-eligible youth.
Where a local program has staff who are locally or privately funded through Wagner-Peyser monies in addition to JTPA funded staff, that program's combined staff could do job development and placement for both the JTPA eligible and non-eligible youth. In order to prevent audit questions, however, the ratio of JTPA funded staff to non-JTPA funded staff should be proportionate to the ratio of JTPA eligible youth to non-eligible youth served. In other words, if there is more than one funding stream for the program, staff could in fact serve both JTPA eligible and non-eligible youth.
Technical assistance. ETA previously transmitted a "how-to" booklet entitled "SummerWorks: A Compendium of 1995 Private Sector Summer Youth Jobs Initiatives and School-to-Work Summer Programs" with Training and Employment Information Notice (TEIN) No. 23-95, dated April 11, 1996. Developed by staff in our San Francisco Regional Office, this booklet is based on a series of interviews with private sector employers and employment and training practitioners active in youth initiatives in Arizona, California, Hawaii and Nevada. Copies of the booklet, along with a cover letter from the Assistant Secretary, have been forwarded to all SDAs.
Transfers. Under anticipated Congressional appropriation language, States will have the authority to transfer unrestricted amounts of FY 96 Title II-B funds to PY 96 Title II-C and vice versa. The Department will notify the States when final appropriation language is enacted. Pursuant to the 1995 rescission bill language, up to 50 percent of PY 94 and PY 95 Title II-B and Title II-C funds may be transferred between the two programs by SDAs, with the Governor's approval. Thus, based on the year of the funds, States have different rules on the transfer of funds between Title II-B and Title II-C.
SDAs can either transfer up to 50 percent of the separate PY 94 and PY 95 allocations, or they can transfer up to 50 percent of the total combined PY 94 and PY 95 allocations, even if that results in a transfer of more than 50 percent of a single program year's allocation. In no instance, however, may the total amount transferred exceed 50 percent of the total PY 1994 and PY 1995 allocations. If the Governor makes the more liberal interpretation, i.e., combining the allocations for the two program years, and approves such transfers, ETA would not disallow costs based upon this interpretation.
Funds transferred are transferred in total (i.e., without regard to cost limits), and SDAs may use the funds in accordance with the appropriate Title II-B or Title II-C rules of the receiving Title and Part. SDAs should use the same reporting as currently provided for under the current transfer policy. (The amounts transferred must be identified on appropriate lines and columns of the JTPA Quarterly Status Report (JQSR).) Expenditures against the transferred amounts are not to be reported separately. In addition, it should be noted that while transfers between Title II-B and Title II-C may occur in either direction, i.e., from Title II-B to Title II-C or Title II-C to Title II-B, they must stay with the year of appropriation, i.e., PY 95 Title II-B can only be transferred to PY 95 Title II-C and vice versa.
Reporting. As part of their oversight responsibilities, Regional Offices will be asked to request, at a minimum, mid- and end-of-program estimates from all States of cumulative enrollments. Further specific information regarding the reporting requirements will be forwarded shortly
Action. States should transmit this guidance to SDAs as expeditiously as possible. In addition, States should instruct SDAs to quickly provide relevant guidance to worksites and service providers.
Inquiries. Questions on this TEGL and other SYETP related questions which may arise should be directed as follows:
Program Issues - Stephanie Curtis (202) 219-7533
Funding Issues - Sherryl Bailey/Jess Aragon (202) 219-7979
Reporting Issues - Jess Aragon (202) 219-7979
JQSR Reporting Instructions
NOTE: Attachment "A" not available to DMS