Department of Labor: SD%20SCSEP%20Program%20Narrative%20PY2006

8/14/2019 Department of Labor: SD%20SCSEP%20Program%20Narrative%20PY2006

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PART 1 PROJECT NARRATIVE

Grant Year July 1, 2006 June 30, 2007

SECTION 1 STATE SENIOR EMPLOYMENT SERVICES COORDINATION PLAN:

How grant application supports the State Senior Services Coordination Plan.

The goals and objectives outlined in the State Senior Services Coordination Plan were

used as a guide in developing this proposal . Any adjustments needed within the state in

regard to service levels were taken into consideration for work to be done in the 2006-

2007 Grant Year.

The issue of placing the older worker and how that can be accomplished is addressed

with steps and plans to make that happen.

SECTION 2 TECHNICAL APPROACH

A. Plan of Action

The South Dakota Department of Labor (SDDOL) will adhere to the guidelines

established for project operations by Title V of the Older Americans Act of 2000, as

amended, the Older Worker Bulletins (OWB) issued by the U.S. Department of Labor,

and other provisions incorporated by this agreement. SDDOL plans to operate the

SCSEP through a Sub-Grant Agreement with Experience Works, Inc. SDDOL maintains

accountability and oversight responsibility for operation of SCSEP.

(1) Recruitment and Selection of Participants

The SCSEP will be operated primarily in rural areas. Many eligible rural seniors live in

isolated communities and are difficult to recruit using traditional recruitment methods.

Consequently, key local organizations, churches, and community leaders will be

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contacted for assistance in identifying individuals with limited income who are 55 and

older in need of SCSEP services. A strong outreach effort will coincide with cooperative

relationships that have been established with aging, employment and training, and social

service organizations. Persons who have been, or who currently are enrolled on the

SCSEP, and former and current Host Agencies, will be encouraged to assist with

recruitment. Brochures, posters, news releases, videotapes, and other public

information materials to assist in recruitment efforts will also be developed.

When practical, vacancies will be listed in local Career Centers. Recruitment activities

generally will be performed by the sub-grantees field representatives and designated

SCSEP participants. Recruitment efforts shall, to the extent possible, ensure equitable

participation by minorities, persons with disabilities, veterans and the spouses of

veterans, persons with limited English-speaking abilities, eligible Native American

individuals, and eligible individuals who have the greatest economic need, at least in

proportion to their numbers in the areas served .

Each applicant's eligibility will be determined by an interview and will be documented on

an eligibility intake form. To be eligible for the program, a person must meet the

following criteria:

a. Be 55 years of age or older;

b. Have declared permanent residence within the state of enrollment;

c. Be eligible to work in accordance with the Immigration Reform andControl Act of 1986 (IRCA); and

d. Be a member of a family whose annual income does not exceed 125

percent of the applicable poverty guidelines, or be an individual who

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receives, or a member of a family that receives regular cash welfare

payments.

e. Be unemployed.

In selecting participants from among eligible applicants, the following priorities will be

adhered to:

(1) Eligible individuals with the greatest social and/or economic need and who are

eligible minorities, limited English speakers, or Native Americans.

(2) Eligible individuals with the greatest economic need.

(3) Eligible individuals over the age of 60.

Following the above listed priorities for participant selection, preference will be given as

follows:

(1) Eligible individuals who are 60 years of age or older and are

a. Veterans and qualified spouses who meet the special consideration criteria (if

feasible)

b. Veterans and qualified spouses who do not meet the special consideration

criteria

c. Non-veterans who meet the special consideration criteria (if feasible)

d. Non-veterans who do not meet the special consideration criteria.

(2) Eligible Individuals who are 55 to 59 years of age and area. Veterans and qualified spouses who meet the special consideration criteria (if

feasible)

b. Veterans and qualified spouses who do not meet the special consideration

criteria

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c. Non-veterans who meet the special consideration criteria (if feasible)

d. Non-veterans who do not meet the special consideration criteria.

An individual's initial and continued eligibility for the SCSEP will be verified and

documented during a face-to-face interview . If documentation is not available to

determine eligibility, the individual may certify eligibility by signing the Income

Worksheets Verification of Eligibility Information form. When such documentation is

available, an applicant's or participant's refusal to produce the substantiating

documentation may result in the denial of enrollment or continued enrollment.

Income eligibility will be computed by counting the individual's actual includable income

by taking the last six months time two, starting with the period preceding the month in

which the application or certification is completed.

(2) Continued Eligibility for Enrollment in the SCSEP

Participants are recertified for continued eligibility at least once within the program year.

Each participants income eligibility will be recertified by computing an annual includable

income with appropriate documentation within the fourth quarter of the grant year .

A participant who is found to be ineligible for continued enrollment at the time of

recertification through no fault of his/her own, or because the participant is over income,

will receive a notice of disqualification for continued enrollment. That notice will inform

the participant that his/her enrollment will terminate in 30 days, explain the reason(s) for

exit, and will explain the participant's right to appeal the finding of ineligibility. When

possible, participants who are found to be ineligible for the SCSEP will be referred to

other sources of employment and income assistance.

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Should a participant be found ineligible for continued enrollment due to an intentional

misrepresentation of fact, that participant shall be given notice of immediate termination

and the reason for the exit . Recovery of all wages and benefits paid to a participant who

obtained SCSEP services by knowingly providing false eligibility information may be

sought. Eligibility records will be kept in each participant file maintained by each field

operations coordinator and in the Regional Service Center in Waco, TX .

(3) Physical Examinations

Host Agency supervisors and training providers will provide reasonable accommodation to

qualified individuals with disabilities as required by the Americans with Disabilities Act unless

providing the accommodation would cause undue hardship. This determination will be based

on the nature and net cost of the accommodation needed and the overall financial resources

of the host agency. Each participant will be offered the opportunity to take a free physical

examination annually (referred to as a health screening). The Health Screening will be

offered upon enrollment or within 60 days after active participation in a community service

training assignment for which the participant receives paid wages and at the time of

recertification and recorded on the Income Worksheet which is maintained in the participant

files in the Regional Service Center and in each field operations coordinators office. The

Health Screening will be performed by a health nurse or other medical practitioner, will be

limited in scope, and will be regarded as a fringe benefit or service to the individual. Host

agencies are encouraged to provide free health screenings for participants assigned to them.

The sub-grantee reserves the right to designate the provider of all health screenings.

Results of the screening will not be reported except voluntarily by the participant unless

required by law and will be maintained in a separate, secure file to maintain confidentiality.

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A participant may be required to have a health screening at any time required by law or when

the Host Agency, the grantee, or a designee possesses a reasonable belief that the

participant's physical or mental condition indicates the potential for harm to the participant or

others. A participants refusal to submit to an examination under these circumstances may

be grounds for disciplinary action, up to and including termination of enrollment.

(4) Orientation

As soon as practical, after a determination of eligibility, each participant will be provided

with orientation. This orientation will generally cover the following types of information: the

SCSEPs and the grantees goals and objectives; SCSEP eligibility; Host Agency

assignments; participant assessment, participant IEP responsibility, evaluation and transfer;

community service training and employment opportunities; hours of work/training; wages

and fringe benefits; supportive services; drug free workplace requirements; maintenance of

effort prohibitions; nepotism; operation of motor vehicle restrictions; work schedules and

time sheets; health and safety; grievance procedures; job search responsibilities;

nondiscrimination and equal opportunity provisions including the right to file a discrimination

complaint with the grantee or the Civil Rights Commission Director; assurances under the

Privacy Act, training opportunities; responsibilities, rights, and duties of the participant and

the Host Agency; permitted and prohibited political activities; and unsubsidized employment

opportunities through local businesses and other services.

Orientation may be conducted by a sub-grantee staff member or a participant assistant, or

through the use of an orientation videotape. The Eligibility Certification/Enrollment Agreement

will document that the participant has received orientation.

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Each Host Agency Supervisor will receive orientation to ensure a clear understanding of

Host Agency rights and responsibilities and program guidelines. This orientation will

generally cover the information included in the sub-grantees calendar/handbook.

(5) Assessment

An assessment of each participant's work history, skills and talents, physical capabilities,

need for supportive services, employment assistance, and training will be performed

prior to or upon enrollment to determine the most suitable available training assignment

for the participant. This assessment may be completed in its entirety on applicants who

have been determined eligible for the SCSEP, but who will not be immediately enrolled

(i.e., who will be placed on a waiting list). Applicants who have been determined eligible,

but for whom positions are not currently available, in essence will receive a "conditional

offer of enrollment," the conditions being the availability of a training position and a

suitable host agency.

The assessment will be made in consultation with the participant and will be based upon the

individual's preferred occupational category, physical capabilities, work history, skills,

aptitudes, career goals, potential for performing community service work assignments,

potential for transition into unsubsidized employment, place of residence, supportive services

needs, and personal interests. Skills testing may be conducted when appropriate to

determine training and/or employment needs.

A copy of an assessment performed by another employment and training provider may

be considered to satisfy the assessment requirement providing the assessment was

prepared within the last 12 months.

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At least twice annually, an assessment will be administered for each participant to

determine if the job aptitudes, readiness and preferences previously established

continue to support the training and supportive needs of the participant or if there is a

need for a revision in the employment plan. This assessment will be documented in the

form of the participants Individual Employment Plan (IEP).

(6) Individual Employment Plan (IEP)

An Individual Employment Plan (IEP) will be developed for each participant based upon

their assessment in partnership with a sub-grantee representative. The initial IEP at

enrollment will identify appropriate goals, employment and quality of life objectives, other

services for the participant, and the strategy to attain goals.

The IEP will be reviewed and updated at least twice in a 12-month period or more often

as needed to determine each participant's potential for transition to unsubsidized

employment, to determine the appropriateness of each participant's assignment, and to

evaluate the progress of each participant in meeting objectives of the employment plan.

IEP updates will include appropriate information to modify the initial and most recent IEP

completed.

Records of participant assessments, IEPs, and evaluations will be maintained as part of

the participant's personnel file.

When a participant refuses to accept at least two referrals or job offers to unsubsidized

employment consistent with his or her IEP, and no extenuating circumstances are

determined, the participant may be exited from the program. The termination shall be

subject to applicable appeal rights.

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(7) Assignment to Community Service

(a) Types of community service activities that will be emphasized in assigning

participants and how they are chosen:

Meaningful training involving the delivery of essential community services that would

not otherwise be provided;

The opportunity to learn new skills and enhance their potential for unsubsidized

employment;

Creation of new community services or the expansion of existing services;

Improvement of direct services to the elderly and to the community in general, and

especially to the economically disadvantaged; or

Involvement of Host Agencies that can and will provide all the support necessary for

participants to carry out their SCSEP training assignments satisfactorily and

ultimately, obtain employment off the program.

Special effort will be made to develop projects involving intergenerational activities and

literacy training as well as to diversify projects and Host Agencies.

(b) Methods used to match participants with community service training - Applicants

and participants will be assigned to Host Agencies based primarily upon individual

assessments of their skills, aptitudes, interests, career goals, and training needs. Other

factors considered in determining agency assignments include local community and

agency needs, the availability of suitable training assignments, and the demonstrated

commitment of qualified agencies to the SCSEP goals and objectives. Efforts will be

made to assign each participant to a Host Agency site in or near the community where

the participant resides. If appropriate, a participant may be assigned to a Host Agency

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site in a neighboring jurisdiction in which the grantee is authorized to operate in order to

provide the best training or employment opportunity for the participant.

A participant may be transferred from a training assignment at any time it is determined

that a transfer would be in the best interest of the participant, the local community, or the

sub-grantee.

Participants may be transferred when necessary to encourage cooperation with

placement goals. Reassignment may also occur when necessary to ensure that

participants and Host Agencies fulfill their duties and obligations.

Participants will not be assigned to projects that would require them to participate in

sectarian religious activities or partisan or nonpartisan political activities. When in the

best interest of the participant, a participant may be placed in a nonpolitical assignment

in a local government office or the office of a local elected official. These assignments

will be closely monitored through field visits and other appropriate methods to ensure

there are no political activities involved.

(c) Extent to which participants will be placed in assignments involving the

administration of the project itself - Participants may be eligible for appointment to

positions such as SCSEP Assistants, Administrative Assistants, Clerical Assistants, and

other positions designed to assist with program administration and to provide directservices to SCSEP participants. Their duties will include helping participants find

employment by preparing resumes, conducting job search skills training, working with

employers to fill temporary, temporary to permanent, and permanent jobs. The duties of

participants in these positions will be based on the needs of the sub-grantees staff

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member to whom he/she reports. Those duties may be very limited in scope and

duration, and may vary from one individual to another.

The sub-grantees director has the discretion to allow participants in administrative

positions to assist with a wide range of functional responsibilities, including but not

limited to recruitment, orientation, assessment, evaluation, visitation, public awareness,

coordination, training/job development, and generation of program income. Participants

in administrative positions must fulfill basic program eligibility requirements. However,

because of their unique contribution to the SCSEP, they may be paid a wage higher than

the minimum wage, and may be assigned to work additional hours, as needed to fulfill

program objectives. Participants will be encouraged to apply for administrative positions

and staff positions, as appropriate, when vacancies occur.

(d) Types of Host Agencies to be used and the procedures and criteria for selecting

work assignments - To be eligible to serve as a Host Agency, an agency must be either:

(1) an agency of local, state or federal government, or (2) a non-profit agency that

performs services for the general public and has obtained 501(c)(3) tax exempt status

from the IRS. Host Agencies will be expected to contribute, in the aggregate, at least

10% of the cost of the Experience Works SCSEP project by providing direct participant

supervision and other necessary resources and support.

Project assignments should generally provide participants with the opportunity to learnnew skills or improve existing skills, develop self-confidence and positive self-esteem,

make a meaningful contribution to his/her community and to the Host Agency, and

obtain training and employment off the program. Participants may not be assigned to

work involving the construction, operation or maintenance of any facility used, or to be

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Workers Compensation

Health Screening (if desired)

(h) Procedures for assuring that participants are given adequate worksite

supervision - Primary responsibility for the day-to-day supervision and training of

participants resides with the Host Agency. Sub-grantee representatives will visit each

worksite, at least semi-annually, to ensure that Host Agencies are providing participants

with the training and job-site supervision necessary for safe, productive, and effective

work, and that the participant's job duties and hours are consistent with applicable

(i) Limit the amount of time in community service: There will not be a set time limit

for participation in SCSEP.

(8) Training During Community Service Assignment and Other Training:

During enrollment, participants generally will receive training designed to promote the

development of new job skills and enhance existing skills; encourage safe work

practices and a healthy work environment; build self-confidence and positive self-

esteem; develop effective job search skills and positive work habits; and provide

information about supportive services, available types of assistance, and issues that

affect them, including but not limited to Social Security benefits, personal health and

nutrition, housing, and tax and retirement laws. Training that is not necessarily related to

a participants Host Agency training assignment, but which could lead to unsubsidized

employment, will be obtained for participants whenever possible through coordination

with educational institutions, literacy councils, the aging network, community-based

organizations, human service agencies, career centers, and job training programs.

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Utilization of the Apprenticeship Program and Disability Program training opportunities

will be emphasized for participants needing this specific training through coordination

efforts. When appropriate the training may be paid by these programs while the wages

for time in training is paid by SCSEP to the participant.

SDDOL plans to utilize On-the-Job Experience (OJE) training to assist participants in

situations where the goal to obtain employment is with an employer that requires specific

skills that are not attainable through a community service assignment. After a minimum

of two weeks at a community service assignment, the participant can be placed on an

OJE. Depending on the circumstances and depth of training required, there may be an

offer to the employer of (1) full reimbursement of wages (100%) for no longer than four

weeks of training; (2) or a 50% reimbursement of wages when training lasts no more

than 12 weeks; or (3) 100% wages paid to the participant when the OJE lasts no more

than 12 weeks. Significant follow-up will be done on a weekly basis to handle problems

and provide support. A participant can only be offered the OJE training opportunity once

in any 12 month period. If the employer provides good training and does retain qualified

participants after the OJE is complete, they may have the opportunity for OJE training

contracts no more than 5 times per year for the same job category.

OJEs can be written with employers across county/state lines. The employer may be

either public or private but not an active host agency. The contract must detail specific

skills to be learned, the timeline and benchmarks to be achieved, the scheduled hoursthe participant is to work each week, and the number of weeks the contract will run.

Information on the significant follow-up for problem resolution must be stated in the

contract. The amount the employer is to be reimbursed or the amount the participant will

be paid (the prevailing wage) must be on the contract. There also needs to be

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training in basic literacy skills, the participant may be assisted by referring him/her to local

service providers or by obtaining the service directly through locally available resources.

When possible, supportive services will be provided to participants at no cost to the SCSEP

and must be consistent with the needs identified in the assessment and documented in the

Individual Employment Plan.

Incidentals necessary for the participant to perform his/her job may be provided, if they are

not available from the Host Agency or other sources. These incidentals may include, but

are not limited to work shoes, uniforms, safety glasses, eyeglasses, rent subsidy, and hand

tools.

Supportive services will be made available as needed to those participants who have been

successful in their job search for the first six months of their employment. These services

are provided through free local resources or paid from SCSEP funds and may include

transportation costs, health care, special job-related or personal counseling, incidentals,

child and adult care or temporary shelter.

(10) Participant Transportation

Every effort will be made to assign participants to training assignments that are within a

reasonable distance of the participant's place of residence. An attempt will also be

made to help participants obtain transportation necessary for unsubsidized employment t

opportunities and to perform their SCSEP assignments by working with the participant's

Host Agency and by accessing other community resources. In appropriate situations

transportation pooling arrangements will be facilitated.

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The participants may be reimbursed directly for transportation costs related to their

SCSEP work assignments, training, and/or job search responsibilities. The

reimbursement rate for participants who use privately owned automobiles for

transportation will not exceed the mileage rate established by the General Services

Administration.

(11) Placement into Unsubsidized Employment

Every participant will be assisted to improve his/her economic condition by obtaining

employment off the program where feasible. Every effort will be made to place 28% (24)

participants by actively promoting the transition of participants into unsubsidized

employment. Participants will be strongly encouraged to use the experience gained

through the community service assignment to acquire new skills or revitalize existing

skills to facilitate successful entry or re-entry into the competitive labor market.

Follow-up surveys will be made of participants placed into unsubsidized employment to

determine the quality and success of the placement. Those follow-up surveys will be

conducted at 30 days after placement and again approximately thirteen months after

placement. The follow-up surveys will normally be done by phone or mail by the sub-

grantees field personnel.

To promote unsubsidized placement, individuals applying for SCSEP enrollment and

agencies applying to be Host Agencies will be informed that eligible seniors will receive

skill training, rather than "permanent" subsidized employment. Efforts will be made to

(1) identify job openings, training resources, and job search assistance for participants,

(2) improve public awareness of the SCSEP and the abilities of older workers, (3)

develop partnerships with private employers and business organizations, and (4)

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coordinate with other employment and training programs, SCSEP sponsors, career

centers, Job Corps, Carl D. Perkins Vocational Education sponsors, the aging network,

and WIA. Staff will utilize local economic development agencies to find where and when

jobs will be coming to communities to approach the businesses about hiring stable older

workers with experience. There will be an emphasis on finding jobs in the health care

industry and hospitality as shown to be growing employment needs in South Dakota.

The U.S. Department of Labor criteria for determining when to count an unsubsidized

placement will be followed. Consistent with past practice, when possible, individuals on

the waiting list will be assisted as well as other unemployed or underemployed

individuals, and other older individuals who need employment. This assistance may

include appropriate referrals to other agencies, resume preparation, job search training,

skills training, placement into temporary, temporary to permanent, and permanent jobs

through a staffing service.

(12) Maximum Duration of Enrollment:

The grantee does not elect to set a maximum duration of participant enrollment in

SCSEP in South Dakota.

(13) Terminations

a) Provision of False Information: Participants intentionally providing false information

for eligibility shall be given notice of immediate termination and the reason for the exit.

Recovery of all wages and benefits paid to a participant in these circumstances may be

sought.

b) Recertification Income Eligibility: Participants found to be ineligible at the time of

recertification through no fault of his/her own will receive a notice of disqualification for

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IEPs will be modified when appropriate to be consistent with mutually agreed upon

changes in the participants goals and plan of action. A minimum of two levels of review

is required prior to exit.

(14) Applicant, Employee and Participant Complaint Resolution

SDDOL, along with the sub-grantee, is committed to providing an environment for its

participants that is free of discrimination based on race, color, religion, sex, national

origin, age, disability, or political affiliation or belief.

The sub-grantee has appointed an Equal Employment Opportunity Officer (EEO

Officer) to ensure nondiscrimination and equal opportunity for the individuals who

participate in SCSEP through the WIA One-Stop System. This EEO Officer is Mr. Bill

Dodson, Human Resources Acting Director, Experience Works, Inc., 2200 Clarendon

Blvd, Suite 1000, Arlington, VA 22201, (703) 522-7272.

Any participant who believes that he or she has been the victim of discrimination should

file a complaint in accordance with the following procedures.

1. Where and When to File a Complaint

A complaint of discrimination should be filed within 180 days with either:

(i) The participants Field Operations Coordinator, the participants Director at

120 S. Indiana Avenue, Sioux Falls, SD 57103, (605) 332-7991; or the EEO

Officer at the addresses listed above; or

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(ii) The Director, Civil Rights Center (CRC), U.S. Department of Labor, 200

Constitution Avenue, N.W., Room N-4123, Washington, D.C. 20210.

2. Form of Complaint

A complaint of discrimination should be detailed and preferably be in writing in order to

assist in understanding and investigation of the complaint. A discrimination complaint

filed with the CRC must be in writing and must include the following information:

(i) The name and address of the complainant or other method of contact;

(ii) A detailed description of the discrimination, including the circumstances in

which it occurred, the dates on which it occurred, and the identities of the

individuals involved; and

(iii) The signature of the complainant or authorized representative.

A complaint may be filed using a Complaint Information and Privacy Act Consent Form.

These forms may be obtained from the EEO Officer or from the CRC.

3. Initial Written Notice

Upon receipt of a complaint of discrimination, the EEO Officer shall immediately give

notice of the complaint to the sub-grantee Director of Human Resources and Legal

Counsel. Within five (5) calendar days of the receipt by the sub-grantee of the

complaint, the sub-grantee shall give Initial Written Notice to the complainant that

contains the following information:

(i) An acknowledgement that the complaint has been received, and

(ii) Notice that the complainant has the right to be represented by an attorney or

other individual of their choice in the complaint process.

4. Written Statement of the Issue(s)

Within 15 calendar days of the receipt of the complaint, the sub-grantee shall give a

Written Statement of the Issue(s) to the complainant that includes the following

information:

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(i) A list of the issues raised in the complaint, and

(ii) For each issue, a statement whether the sub-grantee will accept the issue for

investigation or reject the issue, and the reason for each rejection.

5. Investigation

The sub-grantee shall, as soon as reasonable and practicable after the date of the

Statement of the Issue(s), conduct a fact-finding investigation of the issues raised in the

complaint.

6. Resolution Attempt

After the Investigation is complete, the sub-grantee shall attempt to resolve the

complaint either through direct negotiation with the complainant or through use of

Alternative Dispute Resolution (ADR). The complainant shall have the choice of which

resolution method to use. If the complainant chooses to use ADR, the following

procedures apply:

(i) The sub-grantee shall have the sole responsibility to select the method of

ADR used, i.e., mediation or arbitration, depending on the availability and

cost of the ADR services in locations convenient to both the grantee and the

complainant. The cost of ADR shall be borne evenly by the parties.

(ii) If an agreement is reached under ADR, the sub-grantee shall notify the

complainant that in the event of breach of the agreement, the non-breaching

party may file a complaint with the CRC within 30 days of the date the alleged

breach is discovered.

(iii) If an agreement is not reached under ADR, the sub-grantee shall inform the

complainant that he or she may file a complaint with the CRC within 180 days

of the alleged unfair treatment.

7. Written Notice of Final Action

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Within 90 days of the date on which the complaint was received by the sub-

grantee, a Notice of Final Action shall be sent to the complainant by the sub-grantee.

This Notice shall include the following:

(i) For each issue raised in the complaint, a statement of either the sub-

grantees decision on the issue and an explanation of the reasons underlying

the decision, or a description of the way the parties resolved the issue; and

(ii) Notice to the complainant that he or she has the right to file a grievance with

CRC within 30 days of the date of the Notice of Final Action if he or she is

dissatisfied with the final action taken by the sub-grantee.

Every SCSEP participant will be given the following at application :

Equal Opportunity is the Law

It is against the law for this recipient of Federal financial assistance to discriminate on

the following bases:

Against any individual in the United States, on the basis of race, color, religion, sex,national origin, age, disability, political affiliation or belief; and

Against any beneficiary of programs financially assisted under Title I of the

Workforce Investment Act of 1998 (WIA), on the basis of the beneficiarys

citizenship/status as a lawfully admitted immigrant authorized to work in the United

Stated, or his or her participation in any WIA Title I-financially assisted program or

activity.

The recipient must not discriminate in any of the following areas :

1) Deciding who will be admitted, or have access, to any WIA Title I-financially assisted

program in, or treating any person with regard to, such a program or activity; or

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2) Making employment decisions in the administration of, or in connection with, such a

program or activity.

What to Do if You Believe You Have Experienced Discrimination

If you think that you have been subjected to discrimination under a WIA Title I-financially

assisted program or activity, you may file a complaint within 180 days from the date of

the alleged violation with either:

1) The recipients Equal Opportunity Officer (or the person whom the recipient has

designated for this purpose); or

2) The Director, Civil Rights Center (CRC), U.S. Department of Labor, 200 Constitution

Avenue, NW, Room N-4123, Washington, DC 20210.

If you file your complaint with the recipient, you must wait either until the recipient issues

a written Notice of Final Action, or until 90 days have passed (whichever is sooner),

before filing with the Civil Rights Center (see address above).

If the recipient does not give you a written Notice of Final Action within 90 days of the

day on which you filed your complaint, you do not have to wait for the recipient to issue

that Notice before filing a complaint with the CRC. However, you must file your CRC

complaint within 30 days of the 90-day deadline (in other words, within the 120 days

after the day on which you filed your complaint with the recipient).

If the recipient does give you a written Notice of Final action on your complaint, but you

are dissatisfied with the decision or resolution, you may file a complaint with CRC. You

must file your CRC complaint within 30 days of the date on which you received the

Notice of Final Action.

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preference for veterans and qualified spouses of veterans. Should enrollment

reductions be required from among regular participants, the same priorities will apply.

Temporary Enrollment Agreements/Eligibility Certification forms will be signed by

individuals enrolled for short periods. A copy of these documents will be kept in the

participant's file.

(16) Maintenance of Effort (MOE)

Participants will be placed in Host Agency training assignments that augment existing

services and establish new services that would not otherwise be provided. Project

assignments should increase employment opportunities and not cause:

a. the displacement of currently employed workers, including partial displacement

such as a reduction in hours of non-overtime work, wages, or employment

benefits;

b. the impairment of existing contracts for services;

c. the substitution of Federal funds for other funds in connection with work that

would otherwise be performed; or

d. the substitution of SCSEP services for existing federally assisted jobs.

In addition, participants may not be assigned to work that is the same or substantially the

same as work performed by a person who is on layoff status. The interpretations of

maintenance of effort restrictions contained in the sub-grantees SCSEP Guidelines

manual will be followed absent other guidance from the Department of Labor.

(17) Procedures for Payroll and Payment of Workers Compensation costs

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The payment of participant training costs is done by processing timesheets completed

by the participant and approved by the Host Agency supervisor every two weeks and

submitted by mail or fax to the sub-grantees Regional Service Center. Approximately

$23,000 is paid annually for workers compensation premiums. All workers

compensation premiums will be the responsibility of the sub-grantee to cover. Total

workers compensation medical spent to date for 2005-06 is $43,224.04 and the total

indemnity spent to date is $2110.25.

(18) Collaboration

Strong partnerships with agencies and organizations serving the elderly poor and rural

areas have consistently been developed. To the extent feasible, cooperative

relationships have been established with the Department of Health and Human Services,

Adult Services and Aging, Department of Social Services; other Senior Community

Service Employment Program grantees; Department of Agriculture; Social Security

Administration; career center operators, Workforce Investment/Development Boards,

and other providers of employment and training services; Carl D. Perkins Vocational

Education providers; Vocational Rehabilitation services; and other organizations and

agencies.

The sub-grantee will enhance its ability to serve those who are older and/or

economically disadvantaged by using its SCSEP resources to develop effective

public/private partnerships and cooperative agreements with foundations, corporations,

business organizations, and private employers. Grants/contracts will be developed with

other agencies for the purpose of augmenting existing services and providing critical

services such as outreach assistance, job placement assistance, skills training

assistance, and information on Supplemental Security Income (SSI), food stamps, and

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Factual and technical information will be provided about the SCSEP and their activities

to members of Congress, the state legislature, the Governor, and other elected officials

and their staff. This information will be provided on an on-going basis, and may include

quarterly progress reports, informational visits, annual reports, and the like.

During National Employ the Older Worker Week, the sub-grantee conducts various

activities to promote and highlight the employment of older Americans. As a part of

these activities, a search will be conducted for the outstanding older worker from South

Dakota. The selected honoree attends the Prime Time Award celebration and related

activities held in the Washington, D.C. area in October and the state celebration held in

the honorees home area either before or after the DC event.

Coordination activities will be done with information technologies (IT) companies and

training providers to promote and develop training and employment opportunities for

SCSEP eligible individuals and other unemployed or underemployed mature workers.

Training will be offered via computer labs as identified through collaboration with other

training providers.

(B) Performance Standards and Reporting Requirements

Performance Standards:

The number of authorized positions for this State Plan will be 84 the USDOL determined

state allocated positions awarded to SDDOL by the Governor. SDDOL sub-grants

SCSEP to Experience Works, an agency that is also authorized by USDOL with Federal

slots. The State / Federal programs will be coordinated seamlessly.

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1. SDDOL/Experience Works will place at least 29 percent (24) of the state

allocated positions into unsubsidized employment.

2. SDDOL/Experience Works will serve 157 percent of the authorized positions,

(132) participants based on the state allocated positions.

3. SDDOL/Experience Works will serve 65 percent of the enrollment that are most

in need.

4. SDDOL/Experience Works retention rate has been set at 61 percent by USDOL.

Data Collection and Reporting:

Implementation of the performance standards will be accomplished by training of staff

and staff assistants of the sub-grantee. Spreadsheets and reports have been developed

to track performance. Performance reports will be submitted timely as required.

Reporting requirements will be met use of the existing forms that have been carefully

changed and added to so that all USDOL required information is collected for input into

the national database. Each sub-grantee field staff person currently has a computer with

access to the Internet. Some sub-grantee participant assistants currently also have

computers with the sub-grantees goal to provide all eventually with computers and the

training needed in their use. Data entry responsibilities reside in the sub-grantees

Regional Service Center by staff with excellent computer equipment and access to the

Internet through a Wide Area Network. With time, upgrading of equipment may be

needed for continued processing of the data. Staff and assistants will continuallyreceive training in computer software and completion of forms to assure the information

is accurately collected and entered into the database system. Reports will be generated

on an established schedule for the sub-grantee Director, Manager and field staff.

Should the sub-grantee not remain as operator of this grant, all the files will become the

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property of the grantee. Data is currently uploaded to the SPARQ system from

Experience Works Lawson system. The sub-grantee was found to have excellent

records and provided uploads on schedule.

C. Equitable Distribution

All SCSEP providers of services in South Dakota work cooperatively to improve the

equitable distribution (ED) of SCSEP positions using the 2000 Census data. This new

Census data required very little change in positions per county from the 1990 Census

figures. There are no counties that are significantly over or under-served with a variance

of 1-4 of their equitable share based on the U. S. Census 2000 data. The sub-grantee

Director will participate in equitable distribution meetings and submit ED reports as

requested. If the sub-grantee Director shall continue to be responsible for equitable

distribution in the state, ED meetings will be scheduled to prepare the state ED report

either in person or by telephone.

Any ED imbalances will be corrected through attrition and the transfer of participants.

The displacement of current participants will be avoided whenever possible.

SECTION 3 GEOGRAPHIC AREAS TO BE SERVED

List of where project will be conducted.

Coordination with the private sector and business community will be done to promote

employment and training opportunities for unemployed and/or underemployed older

individuals throughout the state of South Dakota. The specific areas and distribution of

positions is listed in the attached 2006-2007 Authorized Positions-South Dakota

document.

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SECTION 4 PROGRAM ADMINISTRATION

A. Organizational Structure - Grantee

The majority of employment and training programs in the state of South Dakota are

provided under the umbrella of the South Dakota Department of Labor (SDDOL).

SDDOL, through the network of One-Stop Career Centers, has developed a system that

is customer oriented and makes maximum use of current technology to reach the

greatest number of customers. Employers and job seekers have direct access through

Internet technology or personal contact with One-Stop staff to assist in the employment

and training process. The system is able to access the expertise and programs of

partner entities such as education, rehabilitation, economic development, social

services, and others as may be appropriate.

As a single statewide service delivery area (SDA), the leadership and vision for South

Dakotas One-Stop Career Center System has come from the South Dakota Workforce

Development Council (SDWDC). Under this structure, key employment and training

programs like WIA, Wagner-Peyser, Unemployment Insurance, and Veterans'

employment and training programs are brought together with the interests of economic

development, vocational technical education, basic education, and vocational

rehabilitation. South Dakotas system capitalizes on the strengths of education, labor,

rehabilitation, and social services to benefit all segments of our population. Youth,

adults, dislocated workers, disabled individuals, and older workers will have the

opportunity to utilize training and employment services for their individual employment

and training needs. The SDWDC was formed to maintain the momentum for economic

development and vitality by better connecting workforce strategies to economic needs.

The SDWDC is comprised of a majority of private sector members who represent the

state's employers, labor unions, community leaders, and representatives of five state

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agencies including the Secretary of Labor, Secretary of Education and Cultural Affairs,

Secretary of Human Services, Commissioner of the Governor's Office of Economic

Development, and the Executive Director of the Board of Regents. The SDWDC

members share a common purpose: to improve the services to employers and their

current and future employees by streamlining the delivery of workforce and training

services.

B. Subproject Management Sub-Grantee

Experience Works operates under the direction of a President, who also serves as its

chief executive officer. The President directs staff that primarily works out of Experience

Works' national office in Arlington, Virginia. The national staff provides general and

technical support to Experience Works staff assigned to 11 multi-state offices across the

country. Program offices are typically staffed by a Regional Director and appropriate

field and office personnel. Two Regional Service Centers under the leadership of a

Regional Director provide administrative and payroll services to multi-state programs.

Multi-state staff under the leadership of a Regional Director is responsible for the direct

implementation of the program at the local level, from the initial recruitment of

participants and the development of Host Agency assignments to the transition of

participants off the program. Participants are assigned to local Host Agencies who

provide the day-to-day supervision of project activities. Experience Works coordinates

the operations of SCSEP in SD with the multi-state Regional Director.

C. Training of Subproject (Local) Staff

Staff training and development are national priorities for Experience Works. Field and

office staff generally participates in at least one national leadership training conference

annually, attend state and local training programs and seminars, and travel to various

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other state SCSEP and workforce development system projects to observe and learn.

The Regional Director and Manager of Workforce Services have been designated to

ensure that new staff are promptly and properly trained, that existing staff are motivated

and understand program requirements and expectations, and that SCSEP goals and

objectives are achieved. Additional training is provided by a variety of national and state

staff on an "as needed" basis. Information / directives received from USDOL by the

grantee are forwarded as appropriate to the sub-grantees project director.

D. Project Monitoring

SDDOL is responsible for the development, approval and operation of all contracts and

sub-grants, and requires that its contractors and sub-grantees adhere to the

requirements of the Act, the regulations, and other applicable laws. SDDOL also

requires contractors and sub-grantees to maintain effective control and accountability

over all funds, property and other assets covered by a contract or sub-grant. In addition,

SDDOL requires that contractors and sub-grantees maintain and make available for

review by the grantee and Department of Labor all records pertaining to the operations

of programs under the contract and sub-grants. SDDOL has developed a monitoring

system and will conduct regular monitoring of the SCSEP sub-grantee (Experience

Works).

South Dakotas SCSEP has one sub-grantee, Experience Works (EW). Project

monitoring is performed on an annual basis during the recertification phase in the month

of May. The SCSEP State Coordinator visits the regional office where the EW Regional

Director, EW Manager of Workforce Service, EW Field Operations Coordinator (FOC),

and SCSEP participants assemble to conduct training and recertification. During this

time, the SCSEP State Coordinator reviews the SCSEP clients records ensuring

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qualifying criteria for the program is met, and that the records are kept accurate and up

to date. The review includes a random sample of client applications and other

participant records for completeness and accuracies, including the following items:

1. Participant Record Review Eligibility Determination &/or Participant Records

2. Financial Management Integrity Participant Payroll System, Accounting System,

Financial Status Procedures, Cash Management, Procurement, Property Control,

Travel Procedures, and Audits.

3. Administrative Review Staffing and Staff Payroll, Grantee Self-Assessment,

Grantee Linkage Efforts.

4. Validation of Reported Outcomes Financial Status Report and Quarterly Progress

Report.

5. Review of Statements in Planning Documents and Regulatory Requirements

Notice of Intent, Responsibility Review, Program Management Systems, Master

Plan, and Comprehensive Annual Plan.

A formal validation report is generated once the process is complete. We follow-up the

recertification phase with a formal letter identifying what needs to be corrected or a

close-out letter which would indicate the official monitoring has been completed with no

discrepancies. If there were discrepancies that required attention, a close-out letter

would follow after they were corrected.

Experience Works is advised to conduct year-round self-monitoring. Through thisprocess, the project director will be able to identify problems before they disrupt services

or program compliance.

E. Financial Monitoring

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every 18 months, and more frequently if needed. They also receive periodic monitoring

visits by national staff that report directly to the Vice-President for Program Compliance,

and are conducted in accordance with established procedures. The standards for these

compliance reviews include applicable SCSEP regulations and laws, Older Worker

Bulletins, Experience Works policy guidelines and procedures, and Office of

Management and Budget (OMB) Circulars.

Written reports are prepared at the conclusion of each program quality review. These

reports list observations and make recommendations for areas that need improvement,

and provide recommendations to improve or enhance systems affecting program quality

and compliance. Regional/National Directors are required to respond in writing and take

prompt, corrective action in response to findings contained in the program quality

reports. All observations and recommendations must be addressed before closing an

audit. All written monitoring reports and subsequent follow-up responses are made a

part of Experience Works' permanent files.

In the event of questioned costs or an audit disallowance, Experience Works will adhere

to the following policy: Repayment of questioned costs or disallowances resulting from

an isolated and innocent mistake may be waived by the President. Appropriate action

will be taken to prevent the recurrence of such mistakes. However, should the

disallowance be the result of gross negligence or willful misconduct, the President may

demand repayment from any responsible individuals.

F. Audits

Experience Works' audit will be an "organization-wide" audit performed under OMB

Circular A-133 guidelines. An outside accounting firm will perform the audits.

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