Senior Community Service Employment Program (SCSEP)

1. Senior Community Service Employment Program (SCSEP) Overview of SCSEP

2. Table of Contents Section A: Overview of the SCSEP Program – page 3 Section B: U.S. Department of Labor (DOL) and California Department of Aging (CDA) SCSEP Responsibilities – page 9 Section C: CDA Responsibilities to SCSEP Projects – page 12 Section D: SCSEP Project Responsibilities to Participants – page 20 Section E: Project Oversight of Host Agencies – page 51 Section F: Workforce Investment Act (WIA) and One-Stop Career Centers – page 61 Section G: Maintenance of Effort (MOE) – page 64 Section H: SCSEP Record Keeping and Files – page 67 Section I: FYI – Other SCSEP Information – page 74 Section J: Index – page 79

3. Section A: Overview of the SCSEP Program The Purpose of SCSEP History of SCSEP SCSEP Flow Chart Federal Oversight California SCSEP

4. The Purpose of the Senior Community Service Employment Program (SCSEP) • To serve older workers with poor employment prospects • To provide hands-on job training through part-time work at community service agencies • To assist with the transition of participants to unsubsidized employment • To provide supportive services to assist participants to obtain and maintain employment

5. History of SCSEP • 1965 – The SCSEP began as a demonstration project under the Economic Opportunity Act (EOA). The program was incorporated into the Older Americans Act (OAA) in 1973. • Initial program emphasis was to provide low income seniors with useful work experience at community service agencies: Provide participants with job training and job placement Address unmet social service needs in the community • 2000 - The OAA Amendments of 2000 expanded the program’s purpose to increasing participants’ economic self-sufficiency and providing a greater emphasis on placement into unsubsidized employment. • 2006 - The 2006 OAA Amendments reemphasized the focus on community service.

6. SCSEP Flow Chart – Based on Title V of the Older Americans Act (Amended 2006) US Congress Department of Labor (DOL) Employment and Training Administration (ETA) Regional Federal Project Offices & Federal Project Officers (FPOs) Health and Human Service Agency (HHS) Administration on Aging (AoA) State Grantees California California Dept of Aging National Grantees Sub grantees Including AAA Based Projects Host Agencies Participants

7. Federal Oversight • The Department of Labor (DOL), Employment & Training Administration (ETA) administers SCSEP through grants with governmental entities and non-profit organizations: • 56 state and territorial grantees • 18 national grantees

8. 15 CDA SCSEP Providers [Area Agency on Aging (AAA) based]: PSA 5 Marin AAA PSA 8 San Mateo County AAA PSA 9 Alameda County AAA PSA10 Council on Aging of Silicon Valley, Inc. PSA 11 San Joaquin County PSA 14 Fresno-Madera AAA PSA 15 Kings-Tulare AAA PSA 18 Ventura County AAA PSA 19 Los Angeles County AAA PSA 20 San Bernardino County Department of Aging & Adult Services PSA 21County of Riverside Office on Aging PSA 22 Orange County Office on Aging PSA 23 County of San Diego Aging & Independence Services PSA 25 City of Los Angeles Department of Aging PSA 30 Stanislaus County Department of Aging & Veterans Services 8 National Providers and National Organizations: American Association of Retired Persons (AARP) Asociacion Nacional Pro Personas Mayores (ANPPM) Experience Works (EW) National Asian Pacific Center on Aging (NAPCA) National Council on Aging (NCOA) National Indian Council on Aging (NICOA) SER Jobs for Progress National (SER) Senior Service America, Inc. (SSAI) California SCSEP

9. Section B:U.S. Department of Labor (DOL) and California Department of Aging (CDA) SCSEP Responsibilities • DOL Responsibilities to CDA • CDA Responsibilities to DOL

10. DOL Responsibility to CDA • Grant Award • Policy Development • Training and Technical Assistance on Regulations, Policy, and Program Performance Expectations • Issuing Reports and Training and Employment Guidance Letters (TEGLs) • Management of Data Collection and Reporting System • Analyze and Evaluate Overall Effectiveness of the Program Nationally • Provides Data Based on Current Census Data for Equitable Distribution Report

11. CDA Responsibility to DOL • Grant Renewal Narrative and Assurances • Regular Contact with Federal Project Officer (FPO) for Information and Assistance • Performance Improvement Plan (PIP) Development and Implementation • Quarterly Program and Fiscal Reports • Equitable Distribution Report • Data Validation • State Plan

12. Section C: CDA Responsibilities to SCSEP Projects • Distribute Grant Award to Projects • Equitable Distribution of Project Slots Between CDA Projects and Nationals Operating in California • Training and Technical Assistance to Projects • Transmittal of Guidance and Policy to Projects • Aging Network Coordination Requirements • Monitoring of SCSEP Projects

13. Distribute Grant Award to Projects • CDA distributes the DOL grant award to projects through a CDA Program Memo (PM) and Contract Package • The Contract Package includes the PM, award amount, number of slots, contract, program narrative, budget, and programmatic assurances. • Each project is required to submit the following to CDA before receiving their funds: • Program Narrative & Programmatic Assurances • Signed Contract • Budget

14. Equitable Distribution of Project Slots Between CDA Projects and National Grantees Operating in California • Each year CDA meets with the National Grantees who operate in California to determine equitable distribution of project slots • Equitable distribution is based upon each county’s census data • This process ensures SCSEP slots are evenly distributed throughout the state

15. Training and Technical Assistance to Projects • SCSEP analysts provide training and technical assistance to their assigned projects • CDA also provides annual training opportunities to the projects on statutes, regulations, policies, and program requirements

16. Transmittal of Policy Guidance to Projects • CDA transmits DOL policy guidance to projects and Training Employment and Guidance Letters (TEGLs)

17. Aging Network Coordination Requirements • CDA must coordinate with its local state and national providers- State Plan- Equitable Distribution: CDA administers the equitable distribution of participant positions in California • Coordinate with AAAs- Seek supportive services through AAAs

18. Monitoring of SCSEP Projects • CDA conducts regular monitoring of projects ensuring adherence to requirements of OAA, regulations, and other applicable laws • CDA also looks at accountability over all funds, property, and other assets covered by project contract • Reviews all records pertaining to program operations • Make sure that project performance goals are being met

19. What Does the State SCSEP Analyst Monitor? • Local office operation and procedures for eligibility, enrollment, orientation, etc. • Office records (staff and participant files) • Training practices • Unsubsidized placement results and efforts to increase placements • Assessment process procedures; quality of IEP • Host agencies and host agency practices • Relationships with local WIB and One-Stop Career Centers • Observe participants at work in host agencies • Personnel issues • Following written procedures • Complaint resolution process • Work-related accidents • Rotation policy • IEP policy and Evaluations • Obligation to seek unsubsidized employment • Obligation to report income/family size changes • Termination • IEP related • For cause

20. Section D: SCSEP Project Responsibilities to Participants • Recruitment of Eligible Participants and Enrollment Priorities • Eligibility Documentation and Determination (Family, Income, Includable Income for Determining Eligibility, and Excludable Income for Determining Eligibility) • Enrollment and Participant Orientation • Participant Wage and Fringe Benefits (PWFB) • Community Service Assignment - Subsidized Placement • Required Services • Individual Employment Plan (IEP) and Assessments • Specialized (occupational) Training Options • On-the-Job Experience (OJE) Basics and Placement Options (OJE – Projects Must Negotiate a Contract with the Employer) • SCSEP Participant Durational Limits and Waivers • Recertification Requirements • Participant Reassignment or Rotation • Supportive Services Examples • Post-Placement Follow-up First Six (6) Month Period (Retention) • Post Placement Follow-up at 12 Month Period • Participant Termination

21. Recruitment of Eligible Participants • Age - 55 years of Age or Older • Income - Family income may not exceed 125% of the Federal Poverty Guidelines • Unemployed - Participant must be unemployed at time of application and throughout program application • Residence - Participants must reside in the State at time of initial enrollment in which the project is authorized (homeless persons can qualify)

22. Enrollment Priorities • Persons 65 and older OR individuals with: • Veterans/spouses • Disability • Limited English proficiency • Low literacy skills • Rural residence • Low employment prospects • Failed to find employment through Workforce Investment Act programs • Homeless or at risk of homeless

23. Eligibility Documentation • Each project must create a written or electronic format that covers all eligibility documentation requirements (age, income, unemployed, and residency) • The income requirement is based on Total Family Income that must be documented • Must have copies of all documentation on file

24. Eligibility Determination - Family • Definition of a Family – • Husband, Wife, Spouse and Dependent Children; or • Parent or Guardian and Dependent Children; or • Husband and Wife; or • If applicant is claimed as a dependent by a family member with whom they reside on federal tax returns, the CPS definition of family applies • Note: Applicant with a Disability may be Treated as a Family of One

25. Eligibility Determination - Income • Compute the actual includable income for 6 months preceding application or recertification OR • The actual income for the preceding 12 months

26. Includable Incomefor Determining Eligibility • Earnings • 75% of gross Social Security income • Interest and dividend payments • Survivor benefits • Pension or retirement income • Rents, royalties, estates, and trusts • Educational assistance • Alimony • Financial assistance from outside the household • Other incomes

27. Excludable Income for Determining Eligibility • 25% of Social Security income • Public assistance benefits, including income from other E & T programs • Disability income (including SSDI) • SSDI reverts to SS retirement at full retirement age • SSDI/SSI benefits analysis (to determine impact of other programs): SSA.gov/works • All forms of child support • Unemployment compensation • Veterans payments (DOD retirement payments are not excludable) • Workers’ Compensation • First $2,000 of Indian per capita fund distributions • Capital gains (stocks, bonds, house, car; unless applicant is engaged in the business of selling such property) • Withdrawals from bank deposits • Money borrowed • Tax refunds • Gifts, gambling/lottery earnings, lump sum inheritances, and insurance payments • Any other income exception required by Federal law (state provisions have no effect)

28. Enrollment • Enrollment begins when an eligible individual is assigned to a community service assignment • Once assigned, participants get paid for hours related to: • Orientation • Pre-Community Service Training • The actual Host Agency Community Service Assignment • Assistance with Unsubsidized Employment Search

29. Participant Wages & Fringe Benefits (PWFB) • Hours of participation per year • General guideline: 1300 hours per year • On average 18-22 hours per week • Starting date • Assignment to a host agency/community service assignment • Rate of pay • No less than the highest of Federal, state or local, or prevailing wage • Uniform treatment • Participant staff must be treated the same as all other participants

30. Fringe Benefits • Annual physical exam • Sick leave not part of an accrued sick leave policy • Employer-honored federal holidays • FICA • Workers Compensation • Unemployment Insurance – only if state law requires (California does not require unemployment insurance since participants are part of a federally funded training program (Unemployment Insurance Code §634.5(e)(1) & §634.5(e)(2)) • No accrued fringe benefits • Zero balance at the end of each program year

31. Community Service Assignment - Subsidized Placement • Pre-placement activities – Developing the right (best) assignment • MUST be based on assessed strengths and barriers • Training/position description • Supervision and training • Training plan • Rotation as a policy and practice • Monitoring and evaluation • Specialized training • IEP relationship; growth industries • Hours

32. Participant Orientation • Content for Orientation • Wages start with assignment to host agency • Expectation to achieve and retain unsubsidized employment • Assignment is temporary • SCSEP goals and objectives • Community service assignments • Other training opportunities • Available support services • Free physical examination • Participant’s rights and responsibilities • Permitted and prohibited political activities • SCSEP policies and procedures • Grievance procedure • Leave of Absence policy • Participant terminations

33. Required Participant Services • Assessment • Development of an Individual Employment Plan • Community Service Assignment with wages • Referral to One-Stop Career Center (OSCC) for employment services • Job search assistance & counseling • Orientation – includes expectation to achieve and retain unsubsidized employment • Supportive services (includes post employment)

34. Individual Employment Plan (IEP) • A series of stepping stones to an ultimate destination or goal • Participant’s assessment is the starting point • Participant’s goal is the end point; action steps describe how to reach the goal • May be modified at any time • Successful programs update frequently

35. Assessment • Made in partnership with each participant • Consider skills, talents, training, work history, and capabilities • Identify appropriate training & employment objectives • Identify needed supportive services • Must be the basis of the Individual Employment Plan (IEP) • Must be the basis for the host agency assignment • Should be signed by participant and program staff • Must be updated twice per 12 month period

36. SCSEP Funds Can Support • Participant wages while in training plus • Reasonable costs for: • Instructors • Classroom rental • Training supplies and materials • Equipment • Tuition • Other costs of training

37. Specialized (occupational) Training Options • Projects may apply for flexibility in the use of their grant award (75/25 rule) • May submit a plan for the use of up to 10% of their wages and benefits dollars to be used for participant training and supportive services • Specific requirements for use of additional 10% include: • Assurances of continuation of wages payments for individuals involved in training (authorized slot level) • Assurance of no displacement of participants • Explanations of how the use of funds will enhance program effectiveness • Proposed budget and work plan • Contact your CDA SCSEP analyst for more information about the 75/25 rule

38. On the Job Experience (OJE) • Designed to lead to unsubsidized employment with a public or private employer • Useful when participant’s IEP goals require specific skills not attainable through the regular community service assignment • Must provide planned approach and sample contract in grant narrative for DOL approval before beginning OJE on the local level

39. OJE Basics • Participants must first have 2 weeks of community service hours • Do not close out the community service assignment until OJE successfully completed • Needs outlined in participant’s IEP • No Active host agencies • May combine OJE with community service assignment • Only one OJE per participant per 12 month period; only five OJE’s per employer per job category • Training period 12 week maximum • No More than 40 hours per week • Must pay prevailing wage (PWFB)

40. Three OJE Placement Options • Employer may be reimbursed for up to 100% of paid wages if training will last no more than 4 weeks • If OJE more than 4 week, employer may be reimbursed for up to 50% of paid wages for the cost of providing training • Grantee may pay wages of participant directly during OJE

41. OJE – Projects Must Negotiate a Contract with the Employer • Specify: • Skills to be learned • Timelines (hours/week; # of weeks) • Benchmarks the participants must achieve to be hired permanently • Stipulate: • At the end of the training period, if the OJE has been satisfactory, the participant will remain on the employer’s payroll • Amount employer will be reimbursed or participant paid • Who will be responsible for workers compensation

42. SCSEP Participant Durational Limits • Individual time limit for participation: • an individual may remain in the program for up to 48 months • a waiver may be requested to allow a limited number of hard-to-serve individuals to participate beyond the 48 months¹ • 48 month rule took effect July 1, 2007 • Overall grantee average participation cap of 27 months • a waiver may be requested that allows up to a 36 month average participation rate in certain cases² ¹CDA has a DOL approved 48 month durational limit policy with no waivers permitted ²CDA did not request a DOL waiver for 36 months

43. Durational Limits Waiver¹ • Apply to participants with: • Severe disability; • Frail or 75 and older; • Old enough but are not receiving SS Title II; • Severely limited employment prospects in areas of persistent unemployment; and/or • Limited English proficiency or low literacy skills • Must be entered into SPARQ and documented in the participant’s file • Characteristics may be updated over time ¹CDA has a DOL approved 48 month durational limit policy with no waiver permitted

44. Recertification Requirements • Income of each participant must be recertified at least once in a 12 month period; no self-recertification • Pick a date for recertification and adhere to it so that the process becomes automatic – DOL suggests February or March to align with the publication of the Federal Income Guidelines • Income (of all family members) must be documented • Family size must be documented • Ineligible participants: immediate written 30-day notice of termination • Participant referral to other sources of assistance

45. Participant Reassignment or Rotation • Different placement based on the participant’s IEP: • Provide greater opportunity for use of participant’s skills and aptitudes • Provide work experience or training that will enhance unsubsidized placement potential • Otherwise serve in the participant’s best interest • Participants should be considered for rotation to be new training assignment if they have completed their site training and are not being considered for hire

46. Supportive Services • Purpose: to assist participant in successfully participating in community service assignments and to help participant gain and keep a job • Can provide support services during 6-month post-placement period to help ensure retention

47. Examples of Supportive Services • Counseling • Case Management Referrals • Transportation (special provision) • Room and board, if necessary, during training • Periodic group meeting • Incidentals, including but not limited to: • Work shoes • Badges • Uniforms • Safety glasses • Eyeglasses • Hand tools

48. Post-Placement Follow-up First Six Month Period (Retention) • After job placement • Must follow-up for up to six months after placement • Verify continued unsubsidized employment and verify wages • Determine need for supportive services to keep positions

49. Post Placement Follow-up at 12 Month Period • 12 Month post-placement • Verify continued unsubsidized employment and verify wages • Necessitates good case management • Adequate project staffing patterns • Contact beginning of each quarter between CDA-project and project- employer • Employer Customer Satisfaction Surveys

50. Participant Terminations • For Cause • Reasons must be included in the grant application and discussed with the participant at orientation • Written notice detailing the reason for the termination • Non-eligibility (recertification) • 30-day notice in writing • Referral to One-Stop Career Center for further services • IEP-Related • IEP terminations can only be executed if DOL has approved the grantees written policy • Projects policies must include specific reasons for terminations • Policies must be given out at orientation or at a participant meeting • Policies must be contained in the participant handbook or similar document