1DINAP.         Will implementation of the veterans' priority established by the Jobs for Veterans Act (a) cause extensive changes in the way The Indian and Native American Employment and Training Program is administered and (b) is this priority waivable (in the case of those programs that allow waivers)?

RESPONSE:

(a) Except for the focus on veterans P.L. 107-288 will not cause extensive changes in the way the WIA section 166 DINAP is currently administered, either in the field or at the national office level.

(b) This priority can not be waived.

2DINAP.         What process will The Indian and Native Employment and Training Program need to go through in order to assure that its grant award document(s) and/or other applicable governing document(s) formally reflect any necessary changes and requirements?

RESPONSE:

DINAP will issue a DINAP Bulletin with implementation instructions and guidance for the priority provisions of P.L. 107-288. Grantees will have to address this service priority in their comprehensive service plans. Formal inclusion of this priority in section 166 grant documents will also occur.

3DINAP.         Are there any special obligations for The Indian and Native American Employment and Training Program regarding public comment or input on such changes?

RESPONSE:

Generally, no. DINAP does expect some additional questions from section 166 grantees concerning specific situations encountered in the field and may address them in future bulletins. However, if reporting changes must occur, then there will be a "public comment" requirement for Office of Management and Budget (OMB) clearance purposes.

4DINAP.         How is eligibility for The Indian and Native American Employment and Training Program affected?

RESPONSE:

Except for the requirement to provide service priority to eligible veterans, the section 166 eligibility requirements will not change at all - any individual served must still (by law) be an Indian, Alaska Native, or Native Hawaiian as documented by the grantee at time of enrollment and/or program participation.

5DINAP.         Will The Indian and Native American Employment and Training Program be expected to develop or meet any specific performance standards regarding service to veterans?

RESPONSE:

No.

6DINAP.         Who will be responsible for monitoring implementation of the veterans' priority for The Indian and Native American Employment and Training Program?

RESPONSE:

The grant will continue to be monitored and audited in the normal way, with the inclusion of the new requirement. Grantee management and oversight staff are also expected to review the impact of this requirement on their service population.

7DINAP.         Will the Division of Indian and Native American Programs be responsible for annual or special reports on service rendered to veterans?

RESPONSE:

No such "special reports" are anticipated at this time. The current section 166 comprehensive services (i.e., Indian "adult") program report (ETA-9084) tracks the number of veterans served. Unless DINAP expands on this line item, section 166 grantees will only have to report on veterans' status as a participant characteristic, without having to elaborate on the type(s) of services provided to individual veterans.

8DINAP.         Will there be any consequences or ramifications for individual WIA section 166 grantees for failing to provide priority of service to veterans?

RESPONSE:

Like any other statutory requirement, veterans' priority will be an item of individual grantee responsibility, subject to appropriate grievance procedures and appropriate corrective action(s). Failure of any section 166 grantee to abide by said statutory requirements could result in a finding of non-compliance and a sanction.

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