3.Background: The term "equitable distribution" refers to the process of distributing SCSEP positions so that all eligible persons have reasonably equal geographical access to the SCSEP. The Equitable Distribution Report provides a basis for determining the collective progress made by SCSEP grantees toward an equitable distribution of program positions in each State. It is also useful for determining where to locate new or vacant positions and from where to reduce positions, if necessary.
As part of the planning process, grantees must participate in the preparation of an equitable distribution report. It is an integral part of both the State Senior Employment Services Coordination Plan (State Plan) under Section 503 of the amended Older Americans Act (OAA) and the grant application process. The requirement is found at Section 508 of the OAA and 20 CFR Section 641.201(c) of the Federal Regulations.
4.Procedures: In general, procedures for completing this year=s report are similar to those used in previous years. There are some changes, however.
a.) Each grantee operating in the State must sign the report (see section 6.a.(3) below). Please review Attachment I, Special Notes.
b.) Some elements in this report are useful toupdate the State Plan. Grantees in some States may wish to incorporate the Equitable Distribution (ED) report into the Governor=s State Plan updates. Or they may submit the ED plan and later incorporate the same ED plan into the Governor=s State Plan. Attachment II provides instructions for completing the report and the report form.
5.Report Preparation: For each State, The number of authorized positions in the current program year is the same as last year (See Attachment II). The equitable share in each county should be the same as last year. If you wish to update the information, follow the instructions found on page 100 of the user manual, SPONSOR SUPPORT SYSTEM version 1.3, which was transmitted with OW Bulletin 93-11.
Transmit the reports to the Division of Older Worker Programs. This year, the hard copy is the only version we are able to accept, February 28, 2002 is the due date. Contact your Federal Representative if you want a copy of last year=s report.
6. Action:
a. State SCSEP agencies are requested to:
Convene a meeting of all SCSEP program operators in their State to review the existing slot placement, county-by- county;
Develop the sub-State distribution report of the present slot allocations. (A vacant authorized position should be reported, but temporary positions should not.) Compare the equitable levels with the actual distribution, county-by-county, and discuss how to bring about an improved distribution, working to make improvements in the State=s overall distribution.
Obtain the signature of representatives of each grantee operating in the State on the form or the transmittal letter. If a grantee does not sign, it should explain in writing why it did not and send a copy of this explanation to each grantee in the State and to their Federal Representative. NOTE: If a grantee representative is unable to be present physically to sign the form but is in agreement with it, the grantee representative may send a letter indicating agreement in lieu of the signature.
Submit the Equitable Distribution Report to:
Division of Older Worker Programs (DOWP)
U.S. Department of Labor
200 Constitution Avenue, N.W.
Room N4641
Washington, D.C. 20210
b. National SCSEP Grantees should designate representatives to attend State-convened equitable distribution meetings. These representatives should provide existing and projected slot levels to complete the chart. And, they should work with other representatives to bring about more equitable levels county-by-county. It is important that the organizations represented have authority to make changes in the location of their authorized positions.
Completion of the report should be a cooperative activity. All grantees should put forth their best efforts. Disagreements should be resolved locally through good communication and compromise.
7. Format for the Equitable Distribution Report. The attached report form, ETA 8705, should be used for the Equitable Distribution Report. (See Attachment III). To complete the report, sponsors should follow the instructions that are also provided in Attachment II. Although form ETA 8705 should be used, it may be modified by adding pages or expanding or reducing the size of the columns and spaces.
8. Distribution of SCSEP Resources. The OAA requires grantees to seek an equitable distribution of program resources. Where necessary, redistributions should be made by relocation of vacant or new positions and through normal attrition. No enrollee should be terminated simply because of the equitable distribution requirement. The OAA amendments of 2000 provide, at Section 503(a)(6), Adisruptions in the community service employment opportunities for current enrollees is to be avoided, to the greatest possible extent.@
When grant applications are prepared for the next grant period, consideration must be given to the data contained in the Equitable Distribution Report
9. Technical Considerations. The census information was prepared for the Department from information supplied by the U.S. Census Bureau. The data is based on the 1990 census, and includes only those people who meet the statutory participant eligibility factors: individuals age 55 and over who have incomes at or below 125 percent of the poverty level. This information is found on the diskette that was sent to each sponsor with OW Bulletin 93-11. Information for Guam, American Samoa, the
Commonwealth of the Northern Mariana Islands, and the Virgin Islands is not on the diskette. The sponsors in these jurisdictions should use the best available information to complete the chart.
Note: With the exceptions noted above, the data used to prepare the report should be that supplied by the Department of Labor. If a State agency has updated data it wants to use, it should provide that information to the other grantees and their Federal Representative prior to the meeting. The grantees should be given a reasonable amount of time to review the information.
10.Schedule. Reports should be submitted to the DOWP, US DEPARTMENT Of Labor, 200 Constitution Avenue, N.W., Room N-4641, Washington, D.C. 20210, by February 28, 2002.
11.Questions. Questions should be directed to your Federal Representative at
(202) 693-3842 or 3761.
ATTACHMENTS
I Special Notes (below)
II Authorized Positions (below)
III Instructions Form for Completing the Equitable
Distribution Report (below)
Every Grantee in the State must sign the submittal.
Participants in the Equitable Distribution process are reminded of the following points:
* Equitable Distribution should be a cooperative effort. Every grantee in a State should participate. Every grantee must sign the submittal or explain why they did not.
* The Department is interested in as realistic a picture as possible of the distribution of positions within the present slot allocation.
* The report being prepared is for the period July 1, 2001 to June 30, 2002, the current program year. The report should be used to plan next year's application (July 1, 2002 to June 30, 2003).
* Temporary positions do not count. Grantees must use their own judgement to determine whether a position is temporary or not. "Temporary" positions that have been located in the same places for several years should no longer be considered temporary. Permanent positions that have remained vacant for years should be reallocated.
* If a grantee fails to provide the actual location of positions, the preparer of the Equitable Distribution report may use the proposed distribution found in the grant application package as the basis for the delinquent grantee's distribution.
* No enrollee should lose his/her position due to efforts to resolve equitable distribution problems. In this regard, the OAA was amended to include at Section 503(a)(6)... "disruptions in the community service employment opportunities for current enrollees is to be avoided, to the greatest possible extent.@
* All grantees in a State should concur with and sign the report, and each grantee should receive a copy.
* To the extent practicable, grantees should resolve any problems of under-served and over-served areas, striving for equity. The Department recognizes that under certain circumstances, achieving numerical equity may be difficult. For instance, equity is difficult to achieve in rural areas, in counties where there has been a significant historical inequitable distribution, in areas where there have been recent large increases in numbers of eligible persons, and where there are other considerations that impede the equitable distribution of positions. This is an excellent opportunity to consider eliminating duplicate projects in the same area in order to improve administrative efficiency.
Equitable Distribution meetings also provide opportunities for grantees to discuss strategy with regard to membership on State and Local Workforce Investment Boards, content of Memorandums of Understanding with the Local Workforce Investment Boards, and participation in the operation of local One-Stop Career Centers, along with other aspects of implementation of the Workforce Investment Act.
ATTACHMENT III
INSTRUCTIONS FOR COMPLETING THE EQUITABLE DISTRIBUTION REPORT
As required by Sections 508 of the Older Americans Act, and 20 CFR Section 641.202, the State agency for each State receiving funds under Title V must prepare an Equitable Distribution Report. The report should be prepared on a cooperative basis with all grantees in the State participating. It is submitted annually and includes all Senior Community Service Employment Program activities in the State.
To prepare the report, the ETA Form 8705 must be completed using the following instructions:
1. Complete the phrase, "The period ending June 30, A by entering the year 2002. The report is for the program that is currently operating not for the upcoming grant year.
2. Space is provided on the form for entering the name of the State and the date. Please do so.
3. There is a block for "Participating grantees." Please identify the grantees that are in the State. Each grantee must sign the report attesting to their concurrence.
4. Column A "Counties." This column is completed by naming the counties served by the program. Identify the county as urban or rural by using the letters (u) for urban and (r) for rural. Grantees must determine which counties are rural and which are urban.
5. Column B " Distribution Factor." This refers to the mathematical factors, age 55 and above and 125% of poverty, which are used to determine the equitable share of authorized positions in each of the counties listed in Column A.
For example, if Alfalfa county has 20 percent of the State's eligible population, the figure .20 should be placed on the line for that county.
6. Column C "Equitable Share." This column is the numerical result of the factor indicated in the previous column times (X) the authorized slot level. For example, if Alfalfa County has 20 percent of the eligible population in a State, the State's total authorized positions are multiplied by that factor (.20). If there are 100 authorized positions in the State of West Carolina and .20 is the factor, then 100 x .20 = 20. The equitable share for Alfalfa County is 20 authorized positions.
7. Column D "Current Number of Positions": The entry in this column is the number of authorized positions of each grantee operating in the county. List positions by
grantee, but also indicate the total positions for all grantees. The term "current" refers to the authorized positions for the period July 1, 2001 to June 30, 2002 that are
located in the county at the time of the report. Vacant authorized positions should be counted if they are assigned to a specific county.
8. Column E "Difference + or -": This Column is derived by subtracting the column (D) "Current Positions@ from column (C) "Equitable Share" positions. For example, if the equitable share, column (C), is 20 and the number of current positions column (D), is 15, the difference is 5 positions. (20 -15 = 5) This number should be entered in the column as - 5. If there is a surplus of authorized positions in a county, the surplus will be shown as a plus (+). Sponsors must deal in whole numbers/positions.
9. Please complete the last two lines of the report. It would be helpful to include the name and telephone number of the "preparer." We expect every sponsor operating in the State to sign. If a national sponsor has more than one local project operating in the State it may identify one person to sign for all.
NOTE: Grantees are reminded that their cooperation is crucial to the accurate completion of the report. In this regard, please do not make adjustments for the purpose of giving the appearance of an equitable distribution of positions. The report should reflect reality on the date of the report. It is a "snap shot" of the statewide distribution of authorized positions by all grantees - - complete with imbalances and other "blemishes."
