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Attachment Alternative
Trade Adjustment Assistance (ATAA) Questions
and Answers Withholding
1.
Q: Are ATAA benefits taxable income? A: Yes.
ATAA wage subsidies are taxable income.
You will need to issue a 1099 to recipients of the ATAA payments. 2.
Q: Are pensions deductible from ATAA benefits, as
with Unemployment Insurance (UI) payments? A: No. The
Trade Act of 1974, as amended, did not direct that pensions be included in the
calculation of the ATAA wage subsidy. 3.
Q: How do state workforce agencies (SWAs)
determine whether to deduct court- ordered
child support payments from ATAA payments? A: ATAA payments are to be treated in the same
manner as trade readjustment allowances (TRA).
State laws regarding deductions of payments from UI and TRA must follow
the Social Security Act (SSA). SSA Section 303(e)(1) defines “child support
obligations” as “only includ[ing] obligations which are being enforced pursuant
to a plan described in Section 454 of this Act which has been approved by the
Secretary of Health and Human Services under part B of title IV of this
Act.” It therefore does not permit
deductions for alimony or for child support in general, as provided by 20 CFR
617.55(h)(2), but only for child support obligations of the type
specified. Unemployment Insurance
Program Letter No. 45-89 (55 Fed. Reg. 1886 (1990)) explained in
detail the deductions permitted under SSA Section 303(e)(2). ATAA and UI
4.
Q: Must the individual file for a UI claim in
order to be eligible for ATAA? Does the worker have to be eligible for UI to be
eligible for ATAA? A: No.
There is no provision in the Trade Act or TEGL 2-03 that requires an
individual to apply for UI in order to be eligible for the ATAA program. Nor is there a provision that requires an
individual to be eligible for UI. ATAA
and UI are statutorily separate programs.
Eligibility for neither program is dependent on the other program. 5.
Q: Can the ATAA wage subsidy be considered as
income for the purpose of establishing
eligibility for future UI claims? A: The Trade Act does not direct that wage
subsidies be reported as “wages” for UI purposes. However, UI eligibility is governed by state
law. Therefore, states may consult their
own UI law to determine if ATAA meets the state definition of wages for UI
purposes. 6.
Q: How
should the SWA administer recovery of UI overpayments from ATAA, or recovery of ATAA payments from UI? A: ATAA payments are to be treated in the same
manner as trade readjustment allowances (TRA).
Recovery of a state UI overpayment from ATAA is
governed by SSA Section 303(g)(2), requiring an agreement with the Department
before the state may offset ATAA to recover the state UI overpayment. Further, if the state does have such an agreement
with the Department, there is no limit on the amount of the offset from ATAA. Section 243(a)(2) of the Trade
Act limits each deduction from state UI to recover a TAA or ATAA overpayment to
a maximum of 50% of the payment. However, that applies only to the offset
of state UI to recover a TAA or ATAA overpayment. It does not apply to
the offset of TAA or ATAA to recover a state UI overpayment. 7.
Q: Does the ATAA program in any way alter UI rules
in a state? A: No. ATAA
does not change any UI rules. UI must
still be administered in accordance with established instructions. A person receiving ATAA has returned to work
and should be treated like anyone else returning to work. UI payments are not part of the calculation
to determine the ATAA wage subsidy. 8.
Q: If an ATAA recipient is laid off, can he/she
reopen a UI claim that still has an unexpired
benefit year? Does the state issue a
written determination to the individual
suspending ATAA until he/she is reemployed? A. The worker may reopen his/her UI claim that
still has an unexpired benefit year or file a new claim if the benefit year has
ended in accordance with state UI law.
In accordance with TEGL 2-03, Section F, a determination suspending the
ATAA benefit is required if the individual attempts to claim ATAA benefits
after separation. If the worker is
reemployed, he/she may file a new ATAA application. 9. Q: Will the state UI office have the
responsibility for administering the wage subsidy for ATAA recipients as they do for TRA recipients? A: States
have the choice of where they want to locate the responsibility. However, the organizational placement of this payment by the state
must meet Governmental Accounting Standards Board requirements. 10. Q: Do UI laws
apply to ATAA recipients? A. No. An
ATAA recipient is not eligible for UI because he/she is employed on a full-time
basis as defined by state law in the state the worker is employed. Unless otherwise specified in an official
advisory or regulation, no UI-related issue should influence the continued
receipt of the wage subsidy. If,
however, the ATAA recipient becomes unemployed and files for UI, then the state
UI law would be applied to any potential UI entitlement. 11. Q: Is an ATAA
recipient eligible for a new UI claim once the current benefit year expires?
A: No. An
ATAA participant is not eligible for UI unless he/she becomes unemployed, at
which time he/she becomes ineligible for ATAA.
12.
Q: Where does the ATAA wage subsidy fit into the
priority of payments, i.e., UI, Temporary
Extended Unemployment Compensation (TEUC), basic TRA, additional TRA, and remedial TRA? A: ATAA does not fit into this priority of
payments because it is not related to UI.
UI and ATAA are two separate programs that operate independently. UI is for individuals who are unemployed;
ATAA is for individuals who are employed.
Full-Time
Employment
13.
Q: Must re-employment for ATAA purposes be “UI
covered” employment? A: No.
Full-time employment need not be UI covered employment. However, since Section 246 of the Trade Act
requires that a participant in ATAA must be employed full-time as defined by
state law, the state workforce agency (SWA) must determine if the employment
(including self-employment) obtained by the potential ATAA recipient meets the
definition of full-time employment under the applicable state law. 14.
Q: Can self-employment or work involving wages
plus commission or piece work be considered
full-time employment for the purpose of establishing ATAA eligibility? A: Yes.
Self-employment, work involving wages plus commission, or piece work can
be considered full-time employment for the purpose of establishing ATAA
eligibility if such employment meets the definition of full-time employment as
defined by the state. 15.
Q: If self-employment, work involving wages plus
commission, or piece work qualify as
reemployment, how would the income derived from these types of employment be used in calculating the ATAA wage
subsidy? A: The SWA should determine an approximation of
the hourly wage and apply the approximation when calculating the wage subsidy
in accordance with procedures established in TEGL 2-03, Section G. 16.
Q: If a worker applying for ATAA is hired by a
temporary agency for a two-week period,
should the SWA deny ATAA benefits because it is a short-term temporary assignment? A: No. The
ATAA program addresses full-time employment without distinction between
temporary and permanent employment. This
puts additional responsibility on the SWA caseworker who must inform the ATAA
applicant that receipt of an ATAA wage subsidy gives up all future rights to
TRA, job search allowances, and training.
Since in this instance the temporary employment expires after two weeks,
the worker needs to be advised that ATAA payments will cease at the end of the
two weeks, as will eligibility for the Health Coverage Tax Credit (HCTC). 17.
Q: Are workers participating in on-the-job
training (OJT) under TAA or WIA eligible for
the ATAA program? A: No.
While such training is potentially consistent with state definitions of
full-time employment, the federal government is already subsidizing a portion
of the worker’s wages. Payment of the
ATAA wage subsidy would essentially be “double dipping.” This is true whether funded by TAA, WIA, or
any other federal training program. Moreover, if funded by TAA, participation in
OJT training automatically precludes eligibility for ATAA. However,
if a participant in WIA-funded OJT (or any federally subsidized employment from
any funding source except TAA) completes his/her training and obtains full-time
unsubsidized employment before the end of the 26-week ATAA eligibility period,
the individual could be eligible for an ATAA wage subsidy. 18.
Q: In the event that an ATAA recipient’s hours are
reduced to less than full-time, but he or
she remains employed by the employer, does he or she lose ATAA benefits while working less than full-time? A: Yes.
Section 246 of the Trade Act requires that an individual be employed
full-time as defined by state law.
Therefore, any individual whose hours are reduced below full-time, as
defined by state law, loses his/her ATAA benefits, including HCTC
eligibility. It should also be noted
that such an individual remains potentially eligible for ATAA for a period of
up to two years from the date of qualifying reemployment, should such
individual return to full-time work. 19.
Q: Assume that an ATAA participant, who is
employed full-time, is on unpaid leave for
two days during a specific week. Would
the individual be considered to be employed
full-time during this week and eligible for an ATAA wage subsidy? A: The state must look to state law to determine
whether this meets the definition of full-time employment. Continuing Eligibility 20. Q: Section F
(Continuing Eligibility) of TEGL 2-03 states that “In the event of a period of unemployment, workers will need to
complete a new Individual Application for ATAA
upon reemployment.” If an employer has a
regularly scheduled shutdown for one or
two weeks, would the ATAA recipient have to reapply for the wage subsidy after the shutdown is complete or is
reapplication necessary only when an
individual is laid off and finds new employment? A: The state must look to state law to determine
whether this meets the definition of full-time employment. If it is not inconsistent with state law, in
cases where the workers are paid their regular wage during the period of the
shutdown, this does not disqualify them from receiving ATAA. As indicated in Section F (Continuing
Eligibility) of TEGL 2-03, not receiving wages for one full week is considered
unemployment and makes a worker ineligible for ATAA. Moreover, during a regularly scheduled
shut-down for a two-week period where a worker is not receiving wages, the
worker may be eligible for UI for that two-week period. In any case, the worker would not be eligible
for ATAA during this period unless wages were being paid during this period by
the employer. 21.
Q: If a person receiving an ATAA wage subsidy
quits or is fired from his/her job, and finds
another job, can he/she resume receiving the ATAA payment? A: Yes. In
accordance with TEGL 2-03, Section F, a worker can reapply for ATAA when he/she
obtains subsequent employment for up to two years from the date of original
reemployment. 22.
Q: Are all wages and hours from all employment
(including overtime) to be included in
the calculation of the wage subsidy and the calculation of the annual reemployment wage to determine if the
$50,000 limit is exceeded for determining ATAA
eligibility? A: As provided in TEGL 2-03, Section G, overtime
wages are not included in the calculation of the annualized pre-separation or
reemployment wage for determining eligibility for, and the amount of, the ATAA
wage subsidy. Wages from all employment,
excluding overtime pay, would be included in the annualized wage calculation
for both the pre-separation wage and the reemployment wage. 23.
Q: If a worker had a full- and part-time job and
is laid off from the full-time position due
to foreign trade, would his/her part-time wages be included in the formula for calculating pre-separation wages? A: Yes.
Wages from all employment, full- or part-time, are taken into account
when calculating the ATAA wage subsidy. 24.
Q: Why are full- and part-time jobs used to
determine a worker’s annual wages for calculating
an ATAA wage subsidy? A: Section 246 of the Trade Act provides that the
wage subsidy provides 50 percent of the difference between the wages received
by the worker from reemployment and the wages received by the worker at the
time of separation. The statute does not
specify that the reemployment wages include only a single job or that the
pre-separation wages are only those earned in the adversely affected
employment. 25.
Q: Why are overtime wages excluded from a worker’s
annual wage calculation in determining
his or her ATAA wage subsidy? A: Overtime wages are excluded due to their
sporadic nature and the difficulty of projecting the level of such wages. Further, it avoids placing the worker in the
awkward position of choosing whether to accept overtime hours where he/she
either risks losing the ATAA wage subsidy or his/her job. Such a position is contrary to sound
business-friendly practice. 26.
Q: TEGL 2-03 does not permit
telephone certification for establishing continuing eligibility. Documentation
of employment, hours and wages must be provided at each continuing eligibility verification session. Does this requirement apply in those instances where the employer
telephones with the necessary verification information
and the results of that call are documented by state or local TAA staff? A: Yes. The requirement for documentation of
employment, hours, and wages provides hard evidence of the worker’s employment
and serves as a deterrent to fraud.
However, the worker could send a copy of his/her check stub or a letter
from the employer by mail or fax if unable to physically visit the state
office. Amount and
Frequency of Payments 27. Q: TEGL 2-03 requires that the ATAA recipient will receive at least a minimum monthly payment. Can you
explain what this means? A: It means that the ATAA
wage subsidy may be paid on a weekly, biweekly, or other payment frequency but
at a minimum must be paid monthly. This
allows the state to determine what type of payment frequency is most compatible
with the systems it currently uses to pay benefits to recipients. Having at least a monthly payment frequency
does not mean that the worker must receive some minimum amount each month. 28.
Q: Is there a minimum or maximum weekly benefit
amount that can be paid? A: No. The
benefit amount is based on the calculation of the ATAA wage subsidy provided in
TEGL 2-03 and the frequency of the payment. 29.
Q: Can the amount of the ATAA wage subsidy
fluctuate during the course of the two- year
eligibility period? A: Yes. The
amount of the ATAA wage subsidy may vary week by week based on a change in the
hours paid, or hourly wage or wage approximation. The SWA must recalculate the amount of the
ATAA wage subsidy every time the individual returns for the monthly (or more
frequent) verification of continuing eligibility in accordance with TEGL 2-03,
Section G. 30.
Q: In calculating an individual’s ATAA payment,
how does the SWA define the payable
period for an ATAA wage subsidy? A: In accordance with TEGL 2-03, Section G, the
payable period is at the option of the state but in no case should it be less
frequently than monthly. 31.
Q: How do severance pay and wages in lieu of
layoff notice (e.g., 60 day WARN notice
or other employer separation notice) affect the ATAA wage subsidy calculation?
A: Severance pay and wages in lieu of layoff
notice have no effect on the ATAA wage subsidy because the ATAA calculation
should be based on the hourly wage and hours worked during the last full week
of employment as described in TEGL 2-03, Section G. Wages received as severance or in lieu of
layoff notice should not be part of the calculation. 32.
Q: What documentation is acceptable for the
purposes of establishing both initial and continuing
eligibility? A: Depending on the specific eligibility
criterion, documentation may include materials such as a drivers license, birth
certificate, copy of job offer letter, check stub, document referring to date
of qualifying separation, supporting statement from the employer, annual
earnings statements, W-2 forms, and/or other official documentation. 33.
Q: If a worker earned $50 per hour in
pre-separation employment, and later takes a job
at XYZ Corporation at $10 an hour, would the worker receive an ATAA wage subsidy of $800 per week? A: Yes, but in this example the worker will reach
the $10,000 wage subsidy limit in approximately 12 weeks, assuming a 40-hour
week in both the pre-separation employment and reemployment. There is an incentive for workers to take a
job at wages as close to their pre-separation wage as possible in order to
prolong the period in which they receive the ATAA wage subsidy and
correspondingly prolong eligibility for HCTC. 34.
Q: Do SWAs need to keep a computerized record of
all information needed to calculate
and pay an ATAA wage subsidy or can manual methods be utilized? A: The state has the option to maintain
computerized or manual record systems. Funding Source 35.
Q: What is the funding source for ATAA in Fiscal
Year (FY) 2004 and are changes expected
for FY 2005? A: The funding source for ATAA wage subsidies is
the Federal Unemployment Benefit Account (FUBA). The administration of ATAA wage subsidies
will be paid from the State Unemployment Insurance and Employment Service Operations
(SUIESO) account. Instructions for
accessing the SUIESO account for administrative purposes were transmitted to
the states in Unemployment Insurance Program Letter (UIPL) 14-04 on March 1,
2004. Once the methodology is finalized,
it will be made available to states. In
addition, TAA training and associated administrative costs, TRA payments, and
job search and relocation allowances are funded from FUBA. Administration for TRA payments is funded
through SUIESO. Changes are not expected
for FY 2005, but if they occur an official announcement will be prepared. For FY
2004, the total amount available for the wage subsidy program is $10
million. The FY 2005 budget requests an
increased amount for the wage subsidy program.
This request is pending congressional action and has not been approved. Eligibility
Period/Retroactivity
36.
Q: Since the impact date is a year before the
petition date, some workers who are certified
eligible to apply for ATAA will have been separated as much as a year before the certification and will have
become reemployed well before the certification
is issued. In these cases, if workers
apply and qualify for ATAA, can they
receive a retroactive payment for the period they were employed prior to the date of ATAA certification? Could these workers receive a lump-sum
payment of $10,000 if the difference
between pre-separation and reemployment wages were sufficient to warrant such a payment? Would this also apply to workers who do not apply for the subsidy until the end of
the eligibility period? A: TEGL 2-03, Section E, provides that the two
year eligibility period for receiving ATAA payments begins with the first day
of the ATAA qualifying reemployment and that the individual has two years from
that date to apply. This means that the
payments may be made retroactively if the worker has obtained qualifying
reemployment within 26 weeks of layoff and later applies for the program. In addition, a lump-sum payment is possible
if the difference between pre-separation and reemployment wages were sufficient
to warrant such a payment. 37.
Q: What is the rationale for allowing workers two
years from their date of qualifying reemployment
to file their application for ATAA? A: TEGL 2-03, Section E, states that the application
for ATAA must be filed within two years of the first day of qualifying
reemployment. This parallels Section 246
of the TAA Reform Act of 2002, which provides that the ATAA wage subsidy may be
paid over a two-year period. Initial Eligibility
38.
Q: Must a worker be working or just offered
full-time work within 26 weeks of their date
of separation to be eligible for an ATAA wage subsidy? A: TEGL 2-03, Section E, states that the worker
must obtain reemployment by the last day of the 26th week after the
worker’s qualifying separation from TAA/ATAA certified employment. This means that the worker’s first day of
employment must have occurred during the 26-week period. 39. Q: ATAA eligibility requires that the worker may
not return to similar work for the employer
from whom he/she separated. Does
the state define “similar” work? A: Yes.
When an ATAA applicant accepts work with their layoff employer at a
different location, the state is responsible for determining whether the work
is similar. In addition, the individual
cannot return to the division/facility from which he/she was separated, even if
the work is not similar. 40.
Q: If a worker applies for ATAA and is denied
eligibility because annual earnings are in
excess of $50,000, can the worker reapply and be found eligible for ATAA if he/she is separated from this job
(voluntarily or otherwise) and finds new employment
at less than $50,000? A: If the individual is issued a determination
denying eligibility for an ATAA wage subsidy based on the first reemployment
because the reemployment did not meet the conditions to qualify for an ATAA
wage subsidy, and if the individual is subsequently separated and finds a new
job that does meet the conditions for ATAA, then a new ATAA application will have
to be submitted. In this case, since the
first reemployment did not qualify the individual for ATAA it cannot be used to
establish qualifying reemployment within 26 weeks. Therefore, the subsequent full-time
employment must occur within the 26 weeks from the qualifying separation to be
considered for the ATAA subsidy. 41.
Q: In the event a worker applies for ATAA and is
denied by virtue of being 49 years old,
would the worker qualify when he/she turns 50 and is still reemployed? A: TEGL 2-03, Section E, requires that an
individual be 50 years of age at the time of reemployment to be considered for
the ATAA wage subsidy. Therefore, a
worker denied by virtue of being 49 years old would not qualify if he/she turns
50 and is still reemployed in the same job.
However, in the unusual circumstance that the worker becomes separated
from the initial reemployment and is reemployed again within 26 weeks from
his/her qualifying separation and has turned 50, he/she may be eligible for the
ATAA wage subsidy at that time. Benefit Receipt and Point of
Disqualification
42. Q: If a worker
exhausts his/her UI entitlement prior to the 26-week deadline for obtaining reemployment for ATAA purposes,
can that worker receive TRA without
losing all future eligibility for ATAA? A: Yes.
TEGL 2-03, Section E, specifies that workers give up their right to ATAA
when they receive TAA-approved training.
If the worker has exhausted his/her UI eligibility associated with the
first benefit period at the time of layoff, it is possible to receive TRA
benefits with a training waiver during the 26 weeks between layoff and
obtaining qualifying reemployment for ATAA.
Receipt of TRA will not void their right to choose ATAA, not will
receipt of a job search allowance. 43.
Q: Does participation in WIA training prior to or
after TAA certification exclude the worker
from eligibility for the ATAA program? A: WIA training that is not TAA-approved does not
disqualify someone from receiving the ATAA wage subsidy. TEGL 2-03, Section E, specifies that
TAA-approved training does disqualify an individual from receiving the ATAA
wage subsidy. 44. Q: What documentation is necessary to meet the requirement in TEGL 2-03
that a worker must choose between TAA
and ATAA participation? A: While Section E of TEGL
2-03 does not specify a requirement for documenting a worker’s choice between
TAA and ATAA, it does indicate that receipt of the first ATAA wage subsidy or
enrollment in training will attest to this choice. However, states are free to establish their
own documentation requirements for this purpose. 45.
Q: Is it true that workers do not give up rights
to TAA benefits until they receive the first
ATAA payment? A. Yes. Petition Process
46. Q: For ATAA purposes, when determining whether the worker group
possesses “skills that are not easily transferable” to other employment,
will the determination address the
skills of all workers at the affected firm, only the separated workers, all workers over age 50, or only separated workers
over the age of 50? A: The determination
addresses the skills of the petitioning worker group, which may include
individuals both above and below age 50.
47. Q: What does “skills that are not easily
transferable” mean? A: “Skills that are not
easily transferable” refer to a set of skills that do not enable a worker to
quickly obtain employment in a similar kind of work (e.g., a job at an equal or
higher wage and skill level in the local labor market). 48. Q: May
petitioners provide additional documentation in support of the TAA or ATAA petition?
A: Yes. Petitioners may, and are encouraged to,
submit documentation that supports the specific criteria for TAA and/or ATAA
certification with their petition. Existing Certifications
49.
Q: Is there a mechanism to add a request for ATAA
certification to a petition that is already
in process? A: Yes. A
request for ATAA certification can be made on a petition that has been received
but is still under investigation. In
such cases, the petitioner(s) must withdraw the petition and resubmit it with a
request for ATAA certification because the Trade Act requires that an ATAA
program request be made at the time the petition is filed. This would, however, change the impact date
and may lead to workers laid-off more than one year prior to the date of the
resubmitted petition being ineligible for TAA or ATAA certification. 50.
Q: Is there a mechanism to review a TAA
certification in order to add an ATAA certification
where a request for ATAA was not indicated on the original petition? A: No. TEGL
2-03 provides that a request for ATAA consideration must be made at the time
the petition is filed and is consistent with Section 246 of the Trade Act, as
amended. Agent State/Liable State
51.
Q: What are the responsibilities of the agent
state and liable state in administering the ATAA
program? A: For ATAA purposes, the liable/agent state
relationship applies only when a worker loses a job in one state, becomes
reemployed in another, and is eligible for the ATAA wage subsidy. Under the ATAA program, the liable state is
the same as the liable state for the regular TAA program, as described in 20
CFR 617.26(a). In most cases, the liable
state is the state where the worker was working and separated from
employment. The agent state is the state
in which the worker is reemployed. The
distinction has nothing to do with the state where the worker resides. The
responsibilities of the liable state include making all determinations of ATAA
individual eligibility, issuing all redeterminations of individual eligibility
and decisions on appeal, making the ATAA wage subsidy payments, paying
relocation allowances, verifying employment, transmitting names of “eligible
ATAA recipients” to the HCTC program office in the Internal Revenue Service
(IRS), and completing all reports. The
responsibilities of the agent state are cooperating fully with the liable state
and assisting the liable state in carrying out its activities and
functions. The definition of full-time
work for all ATAA participants working in the state is the responsibility of
the agent state. Other responsibilities
include providing interstate ATAA applicants with ATAA program information,
assisting with filing applications, gathering information and forwarding it to
the liable state, and providing the liable state with information needed to
make determinations of ATAA individual eligibility initially and on appeal. Section
426 of the Trade Act specifies that the determination of full-time is based on
the state law of the state where the individual is employed. Therefore, as indicated by the above, the
liable state will have to make ATAA eligibility determinations based on the
agent state’s law. There will be
instances where the agent state and liable state have different definitions of
full-time employment. In these cases,
the liable state will find it necessary to use the agent state’s definition of
full-time employment in making the eligibility determination for the ATAA program. HCTC
52.
Q: If a worker loses eligibility for ATAA due to
separation from employment, does the
worker lose HCTC eligibility? A: Yes. The
person is only eligible for HCTC for any month in which he/she received an ATAA
payment. However, Section 35 of the
Internal Revenue Code of 1986, as amended, provides eligibility for a grace
period of one calendar month after the month in which the worker stops
receiving the ATAA wage subsidy. 53.
Q: Does receipt of only a relocation allowance
under the ATAA program make the individual
worker an “eligible ATAA recipient” for HCTC purposes for that month? A: No. The
definition of an “eligible ATAA recipient” provided in Section 35 of the
Internal Revenue Code is an individual receiving the wage subsidy for that
month. Waivers
54.
Q: Are there reasons where it would be appropriate
to issue training waivers to ATAA-eligible
individuals? A: Workers who are
interested in ATAA but do not yet have qualifying reemployment may wish to
preserve their option to choose between TAA and ATAA while they search for
ATAA-qualifying reemployment, or they may need to access the HCTC. In cases where one of the waver criteria is
met, a waiver could be used to establish HCTC eligibility or to preserve the
worker’s option to access regular TAA benefits if he/she is unable to secure
appropriate ATAA-qualifying reemployment.
Section E of
TEGL 2-03 describes the various options available in granting waivers for these
purposes. The use of waivers should be
evaluated carefully and should also be consistent with guidance contained in
TEGL 11-02 and 11-02, Change 1.
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