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June 30, 1995
OLDER WORKER BULLETIN NO. 95-6
TO: ALL SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM
(SCSEP) SPONSORS
SUBJECT: Placement Indicators
1. Purpose. To seek uniform reporting of unsubsidized placements through out the SCSEP system to obtain
standard placement counts for all grantees toward the 20 percent goal; and to obtain assistance from
grantees in gathering information on nonreportable placement activities which are being performed, but for
which acknowledgement is not being provided.
2. Background. Up to this time, the Department has accepted placement counts based on grantee reporting
with each organization responsible for determining the factors that it used. As a result, the SCSEP has
operated for over 25 years without establishing a uniform definition for unsubsidized placements. This
practice has never been questioned since the SCSEP sponsors traditionally have been very circumspect
about what they counted as placements. Program reviews and studies of the SCSEP found that sponsors
were doing what was identified as a good job of placing older workers at a time when very few other
organizations were attempting to serve this group of individuals.
As the Department reviewed its ability to communicate the very positive story about what is being done by
the SCSEP sponsors, it became apparent that the SCSEP data had limitations which could not be overcome
without establishing uniform practices. To address this matter, the Department issued a proposed Older
Worker Bulletin for comment that grew out of a brainstorming session with a SCSEP work group. There were
a wide variety of comments received on this proposed directive which are addressed in section 3 below.
There was a general consensus on moving forward with this approach so SCSEP grantees could be
recognized for the work they were doing. However, several sponsors asked for an opportunity to discuss the
proposal in-depth in order to strengthen the resulting measures to be used. After conducting follow up
discussions with those sponsors, it became apparent that the sponsors desired a consistent definition. This
would ensure a level playing field within the SCSEP community as well as demonstrating to the outside
community (including the stakeholders and taxpayers), that it is receiving a positive return on the funds that
are appropriated for the SCSEP.
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The resulting outcome of the comment process and further discussions has been to develop a
focused definition that takes into account these factors as well as acknowledging the work being
performed within the SCSEP community. It is anticipated that the measures set forth in this directive
will be supportive of our sponsors' efforts to work with our joint customers, the older workers of this
nation.
3. Comments. First, it is important to address the written comments that were received since the
time and effort taken to respond is appreciated. There were a total of eleven responses to the draft
bulletin. Two of those responding stated that they were in agreement with the indicators as proposed.
The remaining nine commenters raised concerns. Those concerns varied from a preferred sentence
structure to questions about whether the approach would be fair to sponsors, given that other
employment and training programs did not have similar measures. The following is a point-by-point
discussion of the concerns raised, and the Department's responses:
a. Intent of Placement Period. Several points were raised on this item. The positions varied
considerably. One commenter stated that the general intent of the jobs should be that the positions
would be permanent. A contrasting commenter pointed out that the requirement for jobs to last over
90 days overlooks benefits of employment of less than 90 days. Another commenter suggested that
this restriction is not realistic given present labor market conditions. It was pointed out that the path
for many job-seekers is to take several short-term jobs before finding a permanent position.
Department's Response: It is acknowledged that temporary jobs are useful in gaining experience
and providing enrollees with income which would permit them to continue in a training mode in the
SCSEP program upon completion of the short-term. However, placement in a short-term position
should not fulfill the objective of an unsubidized placement for an enrollee in community service.
Therefore, this indicator is not altered for the placement goal. Nevertheless, such placements add
value from the perspective of the enrollee and the employer, our joint customers. To capture this
information, the Department will ask sponsors to voluntarily include this information on non-QPR
counts in their narrative report. This data will be used to describe more adequately what is being
done at the project level for persons who are not familiar with the many positive accomplishments
that the project staff are doing to assist older workers.
b. Placements of Less than 30 Days. One commenter stated that the placement should count
if the intent is met regardless of the actual period that the jobs last. Another commenter stated that
the confirmation of continuing employment should not be retained, or that the 20% goal should be
reduced to offset the loss of placements presently being counted. Still another commenter
recommended that a placement be permitted if a series of placements occurs during a grant period
which
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exceeded the 90-day intent (e.g., 25 days the first time, 20 days the second time, 15 days the third time, 25
days the fourth time and another 20 days the fifth time).
Department's Response: A job placement lasting at least 30 days is a reasonable objective which should be
retained. To count placements of less than 30 days would indirectly encourage short-term placements which
are addressed in "a" above. The 90-day intent and the minimum of 30 days retention are linked, and must be
retained if there is to be a quality aspect to this measure. Therefore, as acknowledged in 3.a. above, data
will be collected on placements which do not meet either the 30 day (temporary) criteria or the 90-day intent.
With regard to a series of placements exceeding 90 days, it appears unlikely that many such situations exist,
but it would be reasonable to permit a placement count when the enrollee is clearly employed for more than
one quarter of the year.
c. Reporting. Two respondents pointed out that since placement confirmations are made 30 days
after the enrollee is placed into an unsubsidized job, there may be reporting difficulties. Specifically,
placements made in the final 30 days of a quarter cannot be validated until the next quarter. In addition, in
the case of placements in the last 30 days of the final (fourth) quarter, the confirmation will be made in the
next grant period.
Department's Response: Since reports are not due at the Department until 30 days after the end of the
quarter, there is some time to confirm some of the late placements before the quarterly report is submitted.
If this cannot be done, the unconfirmed placements should be reported as "other terminations" in the current
quarter and as employment in the subsequent quarterly report if the placement is confirmed. The
unsubsidized placement goal is based on the grant period, and quarterly achievements are less important
than the results of the total grant period.
In regard to the final or fourth quarter report, if there is insufficient time to confirm all the placements before
the report is due, the grantee may seek an extension for submitting the fourth quarter report to the
Department. This can be done by calling the appropriate Federal Representative in the Division of Older
Worker Programs and requesting an extension.
d. When to Count Enrollee Placements. One commenter wanted to know at what point an individual
is considered an enrollee and can be counted. The concern raised was with the phrase "subsequent to
receiving program services." It was suggested that DOL should not establish any requirement for length of
time an individual must be enrolled to be counted.
Department's Response: This concern is similar to a comment raised on the proposed regulations. Several
persons made a comment that credit should be given to SCSEP sponsors who provide placement
assistance for an applicant/enrollee when
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a job opening becomes available, regardless of whether the individual is actually enrolled in a
community service assignment, since it would be in the best interests of the applicant/enrollee. This
is a legitimate concern. The Department is committed to seeking input from the SCSEP community to
determine if there is a desire to report such placements separately from those placed from the
unsubsidized community service assignments.
e. Better-off Economically. This is another area in which contrasting opinions were expressed.
One commenter stated that the goal of the program is that the individual should be better off when
she/he leaves than when starting. Another commenter stated that there should be some assurances
that the individual's income is above the poverty level or better than 125% of the poverty level. At the
same time, it was pointed out that there is a need to permit flexibility in the SCSEP program since it
deals with a different segment of the population than many other programs. Specifically, it was stated
that there needs to be flexibility to address special situations in which accommodations are made to
place persons who are identified as overincome or unable to work full-time due to health reasons.
Department's Response: Such a change is necessary; however, this is a difficult area to address
adequately as was pointed out in the comments. Raising the level of income to poverty level may be
difficult or impossible since many persons opt to take only part-time employment. The phrase "better-off economically" is subject to wide interpretations. Since the intent was to make this as broad as
possible, the phrase would encompass such factors as actual wages, health benefits vs. no health
benefits, subsidized housing versus increased housing costs, transportation, food and shelter. In
addition, it is acknowledged that the language needs to be tightened to make it consistent with the
statement of one of the commenters who pointed out that the individual should be better off than
when he or she entered the program. A list of factors has been included in this directive which will be
used to interpret the phrase, "better-off." It has been left somewhat open-ended to permit grantees to
factor in other economic measures we may not have listed. The starting point for "better-off" will be
when the individual left the SCSEP, since the program should have resulted in assisting the
individual in some manner beyond the initial enrollment.
f. Self-Employment. One commenter indicated that the Department needed to consider self-employment since this resulted in an employed person as much as a placement with another
employer.
Department's Response: The only reason for exclusion of this potential outcome was an oversight
on our part. It should have been included.
g. Self-Placement. One commenter stated that even though self-placement was discarded, it
should be counted since one of the objectives of the SCSEP was to teach the enrollees skills which
will make them self-sufficient.
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Department's Response: The reason for rejecting self-placement was not clearly stated. The intent
was to address self-placement in cases in which there was no connection to the program. When an
individual is provided with job finding skills which result in a placement, such a placement should be
credited to the SCSEP.
h. Attribution. One commenter stated that it would be useful to clarify the meaning of the
phrase "assisted in getting the job", and to specify what documentation would be required. It was
pointed out that unless a reliable instrument for collecting data on attribution is developed, the phrase
dealing with attribution should be deleted.
Department's Response: It is agreed that the attribution based on the individual would create a wide
interpretation. To overcome this shortcoming, the word "individual" will be replaced with the word
"placement" to read: "Employment must occur within 90 days after termination, and the placement
must be attributable to the SCSEP".
i. Applications to Other Employment and Training Programs. There was a concern about the
potential for application beyond SCSEP to other programs. For example, JTPA uses different
situations for entered employment and the period must be 20 hours or more per week to be credited
as a placement for their performance standards. (All placements are reported.)
Department's Response: It is agreed that this indicator would be different for the two programs, but
there are differences in the programs which justify varying measures. There are both legislative and
programmatic differences which mitigate against using the same definitions for JTPA and SCSEP. A
review of the legislative history will show that the 20-hour limitation under the JTPA was directed at II-A programs and was not originally intended for application to Section 204(d). However, due to the
broad construction of the language, Section 204(d) was defined to be covered by the 20-hour
provision. In our opinion, the application of a 20-hour limit to the SCSEP is inappropriate, since many
of the participants only want part-time employment. Fortunately, there is no legislative language
requiring placements of 20 or more hours.
j. Retention. Verbal comments were received which indicated a need to be certain that the
placements provide a lasting value to the former enrollee and the employer. Specifically, it was
recommended that there be a 180-day period for followup. The rationale for suggesting that data be
collected on this factor was related to conversations with Congressional and other reviewers, they
indicated that placements are of minimal value unless they have resulted in the individual continuing
to be employed for a minimum of 180 days with a preference for a full-year period. For those
sponsors who were performing follow-up on a 180-day basis, it was suggested that there were
additional benefits achieved by continuing to work with employers to determine how the individual
was performing as well as becoming aware of other employment opportunities.
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Department's Response: While it is recognized that the Congressional committees and others have
an interest in ensuring that placements result in jobs which provide for a continuing attachment to the
labor market, limited administrative funding may create a burden which all sponsors cannot easily
fulfill. Nevertheless, it would be possible to capture information on whether a job lasts 180 days or
more through a survey that is being proposed in response to the Government Performance and
Results Act. Therefore, no reporting requirement will be imposed at this time to capture this
information on an across-the-board fashion. For those sponsors who are performing the 180-day
follow-up at the present time, it appears to be a useful option to assure placement compatibility and
employer service.
k. Multiple Placements of the Same Individual. A verbal comment was received that indicated
the Department should permit grantees to count placements of individuals even though they may
have previously been placed in the same grant period. The rationale for taking multiple counts of
placements is that the grantee should not be held responsible for what occurs with either the
employer or the former enrollee who returns to the program.
Department's Response. We concur. The recently issued regulation acknowledges that former
enrollees should be given priority to re-enter the program when a placement does not work out as
anticipated. Therefore, sponsors must be able to count multiple placements should a second
placement occur with another employer. However, multiple placements with the same employer
should not be counted.
4. A Context for Placements. The SCSEP is a community service program which provides useful
service to the community in addition to offering unsubsidized placement, supportive services, training
opportunities and other benefits. Unsubsidized employment is an important component of a
successful program, but it is not the only measure of SCSEP project success. It is noteworthy that no
action has ever been taken to penalize a grantee for failure to achieve the unsubsidized placement
goal. Nor does the Department regard practices such as the wholesale enrollment of "job ready"
applicants solely to make unsubsidized placements or to achieve the placement goal to be within the
spirit of the program. At the same time, several sponsors have established a placement goal which
exceeds the Department's own goal.
The placement indicators are intended to ensure that there is general agreement among sponsors on
what constitutes a uniform definition of an unsubsidized placement. These indicators are minimum
measures which contribute to a common understanding of the term "unsubsidized placements."
Individual sponsors may impose more stringent standards on themselves as long as the DOL
minimum requirements are met. For instance, the term "better-off economically" can be defined more
rigorously than our minimum measure. A sponsor could consider placements to be only those that
provide an income above the 125 percent of poverty level. Not
every placement will fit neatly into the indicators described in paragraph 5 below, but these standards
provide a broad context against which judgements on placements can be made.
5. Final Indicators. Based on the input obtained from the SCSEP community, the following quality
tests must be applied before a placement will be counted:
The placement must be confirmed as still
employed after 30 calendar days.
There must be an intent by the employer for the
job to last 90 days at the time of placement.
The individual must be better-off economically
than he/she was under the SCSEP.
Employment must occur within 90 days after
termination, and the placement must attributable
to the SCSEP.
Consistent with the basic principle of continuous improvement, a grantee would determine if all four
of the above indicators were met. If they are met, a placement would be recorded and the total would
be reported in the QPR.
NOTE: The "better-off economically" requirement will be satisfied when an enrollee has been
placed into a job providing income and/or estimated benefits greater than those received
under the SCSEP, or when two of the following criteria are met:
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- hours of employment per week exceed 20 and
the pay is at or above the minimum wage.
- job is consistent with IDP
- free housing is provided
- free food/meals are provided
- health benefits are provided
- reduced cost or free transportation is received
- other economic benefits, not listed above, are received
6. Action Required. SCSEP sponsors are requested to:
a. use the final indicators in section 5 above when recording unsubsidized placements for the
QPR, effective on July 1, 1995; and
b. in the narrative section of the report, share with us the number of placements which fall
outside the above definition so this information can be used to portray more accurately the work
being done by SCSEP sponsors to report the nonQPR placements.
7. Inquiries. Questions should be directed to your Federal Representative on (202) 219-5904.
CHARLES L. ATKINSON AUL A. MAY ND
Chief Director
Division of Older Worker Office of Special Targeted
Programs Programs
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