[Federal Register Volume 59, Number 23 (Thursday, February 3, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-2387]


[[Page Unknown]]

[Federal Register: February 3, 1994]


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Part V





Department of Education





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Department of Labor





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Cooperative Demonstration--School-to-Work Opportunities State 
Implementation Grants Program; Notices
DEPARTMENT OF EDUCATION

DEPARTMENT OF LABOR

 
Cooperative Demonstration--School-to-Work Opportunities State 
Implementation Grants Program

AGENCIES: Department of Education and Department of Labor.

ACTION: Notice of final priority, selection criteria, and other 
requirements for Fiscal Year 1994.

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SUMMARY: The Secretaries of Education and Labor announce an absolute 
priority for awards to be made in fiscal year 1994 to enable States to 
implement plans for statewide School-to-Work Opportunities systems. 
These systems would offer young Americans access to programs designed 
to prepare them for a first job in high-skill, high-wage careers, and 
to increase their opportunities for further education. The Secretaries 
also announce selection criteria that will be applied in evaluating 
applications submitted for this competition.

EFFECTIVE DATE: The provisions in this notice take effect either 45 
days after publication in the Federal Register or later if the Congress 
takes certain adjournments. If you want to know the effective date of 
these provisions, call or write the Department of Education contact 
person.

FOR FURTHER INFORMATION CONTACT: Marian Banfield, U.S. Department of 
Education. Telephone: (202) 205-8838. Or Janet Moore, U.S. Department 
of Labor. Telephone (202) 219-5281. Individuals who use a 
telecommunications device for the deaf (TDD) may call the Federal 
Information Relay Service (FIRS) at 1-800-877-8339 between 8 a.m. and 8 
p.m., Eastern time, Monday through Friday.

SUPPLEMENTARY INFORMATION:

Background

    The Departments of Education and Labor have entered into a 
partnership to establish a national framework within which all States 
can create statewide School-to-Work Opportunities systems. These 
systems will help our youth acquire the knowledge, skills, abilities, 
and labor market information they need to make a smooth and effective 
transition from school to career-oriented work or to further education 
or training.
    Currently, three-fourths of America's high school students enter 
the workforce without baccalaureate degrees. Many of them do not 
possess the basic academic and entry-level occupational skills 
necessary to succeed in the changing workplace. Unemployment among 
American youth is intolerably high, and earnings of high school 
graduates have been falling relative to those with more education. In 
addition, the American workplace is changing in response to heightened 
international competition and new technologies, and these forces, which 
are ultimately beneficial to the Nation, are shrinking the demand for 
and undermining the earning power of unskilled labor. The School-to-
Work Opportunities initiative is the result of a broad-based and 
growing interest in creating school-to-work transition systems in which 
young Americans choose and navigate paths to productive and 
progressively more rewarding roles in the workplace.
    Under the School-to-Work Opportunities initiative and the fiscal 
year 1994 Cooperative Demonstration Program competition, Federal funds 
will be used as ``venture capital'' to stimulate State and local 
creativity in establishing statewide School-to-Work Opportunities 
systems. To achieve this systemic reform, States may choose to build on 
and enrich current promising programs such as tech-prep education, 
career academies, school-to-apprenticeship, cooperative education, 
youth apprenticeship, and business-education compacts, that can be 
developed into programs under a School-to-Work Opportunities system. 
Through the formation of partnerships among secondary and postsecondary 
educational institutions, private and public employers, labor 
organizations, government, community groups, parents, and other key 
groups, communities will take ownership and responsibility for giving 
American youth access to skills and employment opportunities that will 
launch them on paths leading to high-skill, high-wage careers. 
Together, States and localities will take the lead in determining goals 
and priorities, developing new strategies, and measuring progress.
    The Federal role in the School-to-Work Opportunities initiative is 
important, but limited to the establishment of broad national criteria 
and a framework within which States create School-to-Work Opportunities 
systems. The Federal role is to (a) invest in State and local 
initiatives by providing seed capital; (b) help States and localities 
learn from each other and from the experience of our international 
competitors; (c) build a knowledge base of effective school-to-work 
models, including strategies that meet the needs of disadvantaged youth 
and that can be implemented successfully in poor communities; and (d) 
create a national framework through common core criteria and national 
standards.

School-to-Work Opportunities Systems

    The School-to-Work Opportunities initiative provides for a 
substantial degree of State flexibility and experimentation, but all 
State systems will share the following common features and basic 
program components.
    The basis of a School-to-Work Opportunities system is (1) the 
integration of work-based and school-based learning that provides 
students, to the extent practicable, with broad instruction on all 
aspects of the industry students are preparing to enter, (2) the 
integration of occupational and academic learning, and (3) the linking 
of secondary and postsecondary education.
    To build bridges from school-to-work, programs must provide 
students with an integrated array of learning experiences in the 
classroom and at the worksite. In order to ensure that students receive 
these learning experiences, all School-to-Work Opportunities programs 
must incorporate three basic program components: Work-based learning, 
school-based learning, and connecting activities. These three core 
components include--
     Work-based learning that includes providing students with 
a planned program of job training and experiences relevant to a 
student's career and leading to the award of a skill certificate, paid 
work experience, workplace mentoring, and instruction in general 
workplace competencies.
     School-based learning that includes career awareness and 
career exploration and counseling, initial selection of a career major 
by interested students not later than the beginning of the 11th grade, 
a coherent multi-year sequence of instruction typically beginning no 
later than the eleventh grade and ending typically after at least one 
year of postsecondary education tied to high academic and skill 
standards, which would be developed under the proposed ``Goals 2000: 
Educate America Act,'' and regularly scheduled evaluations to identify 
students' academic strengths and weaknesses, academic progress, 
workplace knowledge, and goals; and
     Connecting activities to ensure coordination between the 
work-based and school-based learning components of each School-to-Work 
Opportunities program, which includes matching students with employers' 
work-based learning opportunities, serving as a liaison among employer, 
school, teacher, parent, and student participants, providing technical 
assistance to employers and others in designing work-based learning 
components, providing assistance to students who have completed the 
program in finding appropriate employment, continuing their education, 
or obtaining additional training, collecting information regarding the 
outcome of students' participation in the School-to-Work Opportunities 
program, and linking youth development activities under the School-to-
Work Opportunities program with employers' strategies for upgrading the 
skills of their workers.
    School-to-Work Opportunities programs will result in students 
attaining: (1) A high school diploma or its equivalent, (2) a 
certificate or diploma recognizing successful completion of one or two 
years of postsecondary education, if appropriate, and (3) a skill 
certificate. In addition, these students will be ready to begin a first 
job on a career track and pursue further education and training.

Grant Program Schedule

    The School-to-Work Opportunities initiative is proceeding on two 
funding tracks--(1) during fiscal year 1994, the initiative is being 
funded under current legislative authority in the Job Training 
Partnership Act and the Carl D. Perkins Vocational and Applied 
Technology Education Act (Perkins Act); and (2) for fiscal years 1995 
through 2002, the Departments plan to fund the initiative under the 
proposed ``School-to-Work Opportunities Act of 1993,'' which was 
introduced in Congress on August 5, 1993 as H.R. 2884 and S.1361. The 
funds will be made available through a grants program. The Department 
of Education and the Department of Labor are jointly designing and 
providing for the administration of a State grants program, that 
consists of--
    (a) Development Grants, that are currently being awarded to each 
State for developing a statewide School-to-Work Opportunities plan; and
    (b) Implementation Grants, as described in this notice, awarded 
competitively to States that can demonstrate substantial ability to 
begin full-scale operations and implement the statewide plan.
    The Secretaries have reserved approximately $250,000 in fiscal year 
1994 funds appropriated under the Job Training Partnership Act, to 
assist the Territories in developing and implementing School-to-Work 
Opportunities systems. Specific information regarding the availability 
of these funds will be announced at a later date.
    The efforts that take place under both current authority and the 
proposed legislation are built on a phased-in approach that allows 
States to ``come on line'' at different points in time, depending on 
each State's readiness to undertake broad-scale change and on the 
availability of funds. Development Grants financed from funds requested 
by the Department of Labor under the Job Training Partnership Act began 
to be awarded to States during December, 1993 and are continuing to be 
awarded in January, 1994 to permit States to begin or enhance planning 
and developmental efforts to create comprehensive statewide School-to-
Work Opportunities systems.
    Each Development Grant discussed above is being awarded for a nine-
month period. The Secretaries may make additional Development Grants 
available subsequent to that period to States that do not receive an 
Implementation Grant under this competition, if those States 
demonstrate substantial progress towards developing a comprehensive 
statewide School-to-Work Opportunities plan and if they demonstrate 
that Federal funds will be used effectively.

Implementation Grants Competition

    By this notice, the Secretaries are reserving a portion of the 
funds appropriated under the Perkins Act in fiscal year 1994 for grants 
to States to implement statewide School-to-Work Opportunities systems 
based on State plans. The Secretaries are also establishing selection 
criteria to be applied in evaluating applications for those funds. The 
Secretaries are limiting eligibility for implementation grants to 
States because the Secretaries have concluded that, for this 
competition, the purposes of 34 CFR 426.4(b)(2) can best be achieved by 
awarding grants only to State level applicants. Implementation Grants 
will be funded for up to a five-year period. The Secretaries anticipate 
that continuation awards will be funded under the School-to-Work 
Opportunities legislation, once it is enacted. Although there may be 
certain differences between requirements under the legislation as 
eventually enacted and grant requirements under this notice, the 
Secretaries do not expect these to be fundamental.
    Grantees under this competition will be required to fund local 
partnerships to carry out activities under the School-to-Work 
Opportunities program. The Secretaries intend grantees to fund local 
partnerships through subgrants, as authorized by the fiscal year 1994 
Department of Education Appropriations Act (Pub. L. 103-112).
    On October 14, 1993, the Secretaries of the Departments of 
Education and Labor published a notice of proposed priority and 
proposed selection criteria for this program in the Federal Register 
(58 FR 53388).

    Note: This notice of final priority does not solicit 
applications. A notice inviting applications under this competition 
is published in a separate notice in this issue of the Federal 
Register.

Analysis of Comments and Changes

    In response to the Secretaries' invitation in the notice of 
proposed priority, 27 parties submitted comments. An analysis of the 
comments and of the changes since publication of the notice of proposed 
priority is published as an appendix to this notice.

Changes in the Notice

    In responding to comments received and in developing the final 
notice, the Secretaries have considered the persuasiveness of the 
numerous suggestions made by the various commenters. The Secretaries 
have also considered the House and Senate School-to-Work Opportunities 
bills currently being considered by Congress. The Secretaries have made 
some of the changes suggested by commenters because the Secretaries 
concluded that these changes served to further the purposes of the 
School-to-Work Opportunities initiative. In addition, in the interest 
of facilitating grantees' transition from funding under the Cooperative 
Demonstration authority to funding under the anticipated School-to-Work 
Opportunities legislation, the Secretaries have also made changes that 
are consistent with the Cooperative Demonstration authority in the Carl 
D. Perkins Vocational and Applied Technology Education Act, and, where 
possible, with the House and Senate bills. Ultimately, although there 
may be certain differences between the legislation as enacted and the 
notice, the Secretaries do not expect these to be fundamental. To the 
extent that any differences exist, the Secretaries plan to provide 
grantees with appropriate technical assistance and support in the 
transition from funding under the Cooperative Demonstration authority 
to systems funding under the anticipated School-to-Work Opportunities 
legislation.
    An analysis of the comments and of the changes in the notice since 
publication of the proposed priority and selection criteria is 
published as an appendix to this notice. The following changes made to 
the notice are described in the order that they appear in the notice; 
technical and other minor changes are not addressed:
    (a) Definitions
    (1) ``All students''. Reference to ``students who have dropped out 
of school'' has been added to the definition of the term ``All 
students'' to clarify that drop-out youth are included within the term 
and that, therefore, drop-out youth are intended to be served under the 
School-to-Work Opportunities program.
    (2) ``All aspects of the industry''. The term ``Elements of an 
industry'' has been replaced by the term ``All aspects of the 
industry'' for the purpose of achieving consistency with the proposed 
School-to-Work Opportunities legislation, as well as with the Carl D. 
Perkins Vocational and Applied Technology Education Act, both of which 
utilize the term ``all aspects of the industry.'' In defining the term, 
the Secretaries have chosen to apply the definition contained in 34 CFR 
400.4(b) of the regulations implementing the Perkins Act. The use of 
the term ``All aspects of the industry'' rather than ``Elements of the 
industry'' is not intended to affect a change upon this competition or 
upon the requirements contained in the notice.
    (3) ``Career major''. Paragraph (d) of the definition of ``Career 
major'' has been revised to indicate that a student participating in a 
School-to-Work Opportunities program may satisfy the requirement for a 
high school diploma by earning the ``equivalent'' of a high school 
diploma. The determination of what is the ``equivalent'' of a high 
school diploma is left to each State. Paragraph (e) of the definition 
of ``Career major'' has been revised by adding the clause ``or 
admission into a degree granting college or university.'' This change 
is meant to clarify that admission into a degree-granting college or 
university is one example of the further education and training to 
which a career major may lead.
    (4) ``Partnership''. The definition of the term ``Partnership'' has 
been revised by adding the words ``non-managerial'' before the word 
``employee''. The intent is to clarify what type of employee is being 
referred to in the reference to ``labor organizations or employee 
representatives.'' The Secretaries consider it likely that managerial 
employees will be represented within the category of ``employers.'' In 
addition, the definition of ``Partnership'' has been revised to include 
within the illustrative list of ``other entities'' that may be included 
in a partnership national trade associations working at the local 
level; proprietary institutions of higher education, as defined in 
section 481(b) of the Higher Education Act of 1965 (20 U.S.C. 1088(b)), 
which continue to meet the eligibility and certification requirements 
under section 498 of such Act; and vocational student organizations.
    (5) ``Skill certificate''. The definition of the term ``Skill 
certificate'' has been revised to clarify that the term is intended to 
refer to a portable, industry-recognized credential, that certifies 
that a student has mastered skills that are benchmarked to high-quality 
standards. In addition, under the revised definition, prior to the 
development of skill standards under the proposed Goals 2000: Educate 
America Act, States are required to develop skill standards under a 
process described in their plan. Those standards also must be 
benchmarked to high-quality standards.
    (6) ``Workplace mentor''. The definition of the term ``Workplace 
mentor'' has been revised to clarify that a workplace mentor may be 
either an employee at the workplace in which work-based learning is 
being provided, or another individual approved by the employer. This 
revision makes clear that individuals such as special educators, 
vocational rehabilitation counselors, job coaches, and work-study 
coordinators, may serve as workplace mentors for all students, 
including, in particular, students with disabilities. In addition, the 
definition has been revised to require workplace mentors to possess 
both the skills and knowledge to be mastered by the student whom they 
are mentoring in the workplace.
    (b) Absolute Priority
    (1) Collaboration with appropriate officials (Paragraph (b)(2)). 
The priority has been revised to require collaboration with the State 
educational agency rather than the chief State school officer in the 
implementation of School-to-Work Opportunities systems. The Secretaries 
have made this change in order to be consistent with both the House and 
Senate bills. A corresponding change has been made to paragraph (b)(1) 
of the selection criterion ``Collaboration and Involvement by Key 
Partners.''
    (2) Active and continued involvement of interested parties 
(paragraph (b)(3)). The priority has been revised to include a 
reference to ``related services personnel'' following the reference to 
teachers, in the illustrative list of interested parties whose active 
and continued involvement in States' School-to-Work Opportunities 
systems may be obtained by States. In addition, in the interest of 
consistency with the proposed School-to-Work Opportunities legislation 
that is expected to govern future funding of State School-to-Work 
Opportunities systems and in response to comments, the Secretaries have 
added human services agencies, language minority communities, Private 
Industry Councils established under the Job Training Partnership Act, 
vocational student organizations, and State or regional cooperative 
education associations, to the illustrative list of interested parties.
    (3) Coordination of the use of funds (paragraph (b)(4)). The 
priority has been revised to include the Job Opportunities Basic Skills 
Training Program, authorized under part F, title IV, of the Social 
Security Act (42 U.S.C. 681 et seq.), programs of the National and 
Community Service Act of 1990 (42 U.S.C. 12501 et seq.), and programs 
of the Higher Education Act of 1965 (20 U.S.C. 1001 et seq.), among the 
related Federal programs with which States are directed to coordinate 
their School-to-Work Opportunities systems.
    (4) State training strategies (new paragraph (b)(5)). The priority 
has been revised to include a new paragraph (b)(5) requiring that 
States describe their strategies for providing training for teachers, 
employers, mentors, counselors, and other parties in the States' 
School-to-Work Opportunities systems. The Secretaries view this change 
as being consistent with the intent of the School-to-Work Opportunities 
initiative which calls for innovation and fundamental change in States' 
secondary school academic and skill training.
    (5) Ensuring opportunities for young women to participate 
(paragraph (b)(8)). The priority has been revised so that, rather than 
being required simply to describe how States will ensure opportunities 
for young women to participate in School-to-Work Opportunities 
programs, States are required to describe the goals and the methods 
that they will use, such as awareness and outreach, to ensure 
opportunities for young women to participate in School-to-Work 
Opportunities programs in a manner that leads to employment in high-
performance, high-paying jobs in non-traditional employment.
    (6) Ensuring opportunities leading to employment (paragraph 
(b)(9)). The priority has been revised to clarify that States must 
describe how they will ensure opportunities for low-achieving students, 
students with disabilities, and drop-outs, to participate in School-to-
Work Opportunities programs in a manner that leads to employment in 
high-performance, high-paying jobs. This revision renders paragraph 
(b)(9) consistent with paragraph (b)(8), under which States must 
describe how they will ensure similar opportunities for young women to 
participate.
    (7) Service to areas with high concentrations of poor and 
disadvantaged youth (paragraph (b)(13)). The priority has been revised 
to require States to describe: (1) How their systems will be expanded 
over time to cover all geographic areas and (2) how proposed School-to-
Work Opportunities systems will address the needs of students from all 
communities, including areas with high concentrations of poor and 
disadvantaged youth. (A parallel change has been made to the 
``Comprehensive Statewide System'' selection criterion.)
    (c) General Program Requirements
    (1) Basic Program Components. The ``General Program Requirements'' 
section, containing the basic components of the School-to-Work 
Opportunities program, has been revised to indicate that the high 
school diploma requirement may be satisfied when a student is awarded 
the ``equivalent'' of a high school diploma, as determined under 
standards developed by the State. (Parallel changes have been made to 
the definition of the term ``career major'' and to paragraph (e) of the 
``Local Programs'' criterion.) In addition, paragraph (a)(1) of the 
``General Program Requirements'' section of the priority has been 
revised to provide that one of the bases of a School-to-Work 
Opportunities system is the integration of work-based learning and 
school-based learning ``that provides participating students, to the 
extent practicable, with broad instruction in all aspects of the 
industry the students are preparing to enter.'' (As previously noted, a 
definition of the term ``all aspects of the industry'' has been 
provided in the ``Definitions'' section of this notice.)
    (2) Work-based Learning. The reference to ``Broad instruction in a 
variety of elements of an industry'' has been deleted from the work-
based learning component of the ``General Program Requirements'' 
section, since reference to broad instruction in all aspects of the 
industry that students are preparing to enter is now made in paragraph 
(a)(1) of the basic components section of the priority. (See discussion 
above in paragraph (c)(1) of this summary).
    (3) School-based Learning. The school-based learning component has 
been revised to require, among other stated elements, ``career 
awareness and career exploration and counseling (beginning at the 
earliest possible age)'' in order to help interested students to 
identify, select, or reconsider, their interests, goals, and career 
majors, ``including those options that may not be traditional for their 
gender, race, or ethnicity.'' This change makes clear that promotion of 
career awareness and exploration of all career options, at an early 
age, is desirable. The determination of the age at which career 
awareness, career exploration, and counseling should appropriately 
begin, is left to the States. And, the section of the school-based 
learning component containing the requirement for regularly scheduled 
evaluations has been revised to require those evaluations to identify 
students' academic strengths, weaknesses, and ``academic progress, 
workplace knowledge, and goals * * *.''
    (4) Connecting Activities. The connecting activities component has 
been revised to include, among other required elements, ``Providing 
assistance to schools and employers to integrate school-based and work-
based learning and integrate academic and occupational learning.'' In 
addition, the Secretaries have revised this component to provide an 
illustrative list of post program outcome information that grantees may 
include among the types of information they collect. The list includes 
information on gender, race, ethnicity, socio-economic background, 
limited-English proficiency, and disability.
    (d) Examples of Statewide Activities. Reference to ``related 
services personnel'' has been added to the list of those individuals in 
paragraph (c) for whom training could be provided by a grantee under 
this priority. In addition, the outreach activities in paragraph (b) 
have been revised to include the clause ``stimulating the development 
of partnerships in poor communities.'' And, paragraph (h) has been 
added to provide that States may work with ``localities to recruit and 
retain all students in School-to-Work Opportunities programs, including 
those from a broad range of backgrounds and circumstances.''
    (e) Allocation of Funds to Local Partnerships. When the notice of 
proposed priority was published, the Departments did not have the 
authority to require States to award subgrants to local partnerships 
with funds awarded under this competition. The 1994 Department of 
Education Appropriation Act (Pub. L. 103-112), included a provision 
authorizing grantees of funds under this competition to make subgrants 
to localities for carrying out School-to-Work Opportunities projects. 
In light of this new authority, the notice has been modified so that it 
now requires States receiving School-to-Work Opportunities 
Implementation grants under this competition to distribute to local 
partnerships 65 percent of the amounts they receive, as subgrants to 
localities. Under the pending legislation, we expect that this amount 
will increase to 75 percent in the second year, and 85 percent in each 
year thereafter.
    (f) Examples of Activities for Local Partnerships. New paragraphs 
(f), (l), (m), and (n) have been added so that included among allowable 
activities for local partnerships are: providing career exploration and 
awareness services, counseling and mentoring services, college 
awareness, and other services to prepare students for the transition 
from school to work; designing local strategies to provide adequate 
planning time and staff development activities for teachers, school 
counselors, and related services personnel; enhancing linkages between 
after school, weekend, and summer jobs, and opportunities for career 
exploration and school-based learning; and conducting outreach to all 
students in a manner that most appropriately meets their needs and the 
needs of their communities. Redesignated paragraph (g) has been changed 
to specifically include disabled students in graduation assistance 
programs.
    (g) Safeguards. A reference to labor standards has been added to 
paragraph (d) under ``Safeguards,'' to clarify that all existing labor 
standards must be applied to School-to-Work Opportunities systems 
funded under this competition. Under paragraph (d) as revised, States 
are required to provide all students with adequate and safe equipment 
and a safe and healthful workplace in conformity with all health, 
safety, and labor standards of Federal, State, and local law.
    (h) Selection Criteria for Evaluating Applications. In the 
discussion of the application review process, the Secretaries have 
clarified that, among the factors upon which the Secretaries will base 
their funding decisions are the replicability, sustainability, and 
innovation of the School-to-Work Opportunities plans described in the 
States' applications.
    (i) Selection Criteria 
    (1) Comprehensive Statewide System. In the ``Comprehensive 
Statewide System'' criterion, the Secretaries have made a revision to 
clarify that each State must propose a feasible plan for expanding the 
School-to-Work Opportunities system so that students in all parts of 
the State, including communities with high concentrations of poor and 
disadvantaged youth, will have the opportunity to participate in the 
State's School-to-Work Opportunities program within a reasonable period 
of time. This criterion is intended to ensure that State skill 
standards and methods of skill assessment are benchmarked to high 
quality standards and that students receiving skill certificates under 
the School-to-Work Opportunities program will have the opportunity to 
enter high-skill, high-wage, employment. Accordingly, the question 
``Does the State's process for assessing skills reflect the needs of 
high performance workplaces as well as meet the requirements of broad 
clusters of related occupations and industries, rather than those of 
individual jobs or occupations?'' has been added to this criterion.
    (2) Involvement by Key Parties. Under this criterion, States will 
be evaluated on whether they propose effective and convincing 
strategies for obtaining the active and continued involvement in the 
School-to-Work Opportunities program of employers and other interested 
parties within the State. The criterion has been revised to reflect the 
Secretaries' intent that each State obtain input, from employers and 
other key parties, on the State's plans for a proposed School-to-Work 
Opportunities system, prior to submitting an application for funds 
under this competition.
    (3) Resources. The ``Resources'' selection criterion has been 
revised to include the question: ``Does the applicant limit 
administrative costs in order to maximize the amounts spent on delivery 
of services to students enrolled in School-to-Work Opportunities 
programs?'' Accordingly, applications will be reviewed to ascertain, 
among other things, whether States are planning to limit State and 
local partnership administrative costs in order to direct as large a 
portion of the funds received as possible toward providing academic and 
training services to students participating in their School-to-Work 
Opportunities programs.
    (4) Student Participation. The ``Student Participation'' selection 
criterion has been revised to include ``students with limited-English 
proficiency and academically talented students.'' The intent is to be 
consistent with the definition of the term ``All students'' (and to 
further clarify that School-to-Work Opportunities systems are intended 
to meet the needs of academically talented students).

Cooperative Demonstration--School-To-Work Opportunities 
Implementation Grants


Definitions

    As used in this notice--
    ``All aspects of an industry'' includes, with respect to a 
particular industry that a student is preparing to enter, planning, 
management, finances, technical and production skills, underlying 
principles of technology, labor and community issues, health and 
safety, and environmental issues related to that industry;
    ``All students'' means students from a broad range of backgrounds 
and circumstances, including disadvantaged students, students of 
diverse racial, ethnic, and cultural backgrounds, students with 
disabilities, students with limited-English proficiency, students who 
have dropped out of school, and academically talented students;
    ``Career major'' means a coherent sequence of courses or field of 
study that prepares a student for a first job and that--
    (a) Integrates occupational and academic learning, integrates work-
based and school-based learning, and establishes linkages between 
secondary and postsecondary education;
    (b) Prepares the student for employment in broad occupational 
clusters or industry sectors;
    (c) Typically includes at least two years of secondary school and 
one or two years of postsecondary education;
    (d) Results in the award of a high school diploma or its 
equivalent, a certificate or diploma recognizing successful completion 
of one or two years of postsecondary education (if appropriate), and a 
skill certificate; and
    (e) May lead to further training, such as entry into a registered 
apprenticeship program, or admission into a degree-granting college or 
university.
    ``Partnership'' means a local entity that is responsible for local 
School-to-Work Opportunities programs and that consists of employers, 
public secondary and postsecondary educational institutions or 
agencies, and labor organizations or non-managerial employee 
representatives, and may include other entities, such as non-profit or 
community-based organizations, rehabilitation agencies and 
organizations, registered apprenticeship agencies, local vocational 
education entities, local government agencies, parent organizations and 
teacher organizations, Private Industry Councils established under the 
Job Training Partnership Act, national trade associations working at 
the local levels, proprietary institutions of higher education (as 
defined in section 481(b) of the Higher Education Act of 1965 (20 
U.S.C. 1088(b)), that continue to meet the eligibility and 
certification requirements under section 498 of the Higher Education 
Act of 1965, vocational student organizations, and Federally recognized 
Indian tribes and Alaska Native villages;
    ``Skill certificate'' means a portable, industry-recognized 
credential issued by a School-to-Work Opportunities program under an 
approved plan, that certifies that a student has mastered skills that 
are benchmarked to high quality standards, such as the skill standards 
envisioned in the proposed Goals 2000: Educate America Act, except that 
until such skill standards are developed under the Act, the term 
``skill certificate'' means a credential certifying that a student has 
mastered skills that are benchmarked to high quality standards, issued 
under a process described in a State's approved plan;
    ``Workplace mentor'' means an employee at the workplace, or another 
individual approved by the employer, who possesses the skills and 
knowledge to be mastered by a student, and who instructs the student, 
critiques the student's performance, challenges the student to perform 
well, and works in consultation with classroom teachers and the 
employer.

Absolute Priority

    Under 34 CFR 75.105(c)(3), the Secretaries of the Departments of 
Education and Labor give an absolute preference to applications that--
    (a) Are submitted by States; and
    (b) Propose to implement statewide School-to-Work Opportunities 
plans that are included in the applications and that--
    (1) Designate the geographical areas to be served by partnerships, 
which shall, to the extent feasible, reflect local labor market areas;
    (2) Describe the manner in which the Governor; the State 
educational agency; the State agency officials responsible for job 
training and employment, economic development and postsecondary 
education; and other appropriate officials, will collaborate in the 
implementation of the State School-to-Work Opportunities system;
    (3) Describe the manner in which the State has obtained and will 
continue to obtain the active and continued involvement in the 
statewide School-to-Work Opportunities system of employers and other 
interested parties such as locally elected officials, secondary and 
postsecondary educational institutions or agencies, business 
associations, employees, labor organizations or associations thereof, 
teachers, related services personnel, students, parents, community-
based organizations, rehabilitation agencies and organizations, 
registered apprenticeship agencies, human services agencies, language 
minority communities, Private Industry Councils established under the 
Job Training Partnership Act, vocational student organizations, State 
or regional cooperative education associations, and local vocational 
educational agencies;
    (4) Describe the manner in which the School-to-Work Opportunities 
system will coordinate with or integrate local school-to-work programs, 
including programs financed from State and private sources with funds 
available from related Federal programs such as the Adult Education Act 
(20 U.S.C. 1201 et seq.), the Carl D. Perkins Vocational and Applied 
Technology Education Act (20 U.S.C. 2301 et seq.), the Elementary and 
Secondary Education Act of 1965 (20 U.S.C. 2701 et seq.), the Higher 
Education Act of 1965 (20 U.S.C. 1001 et seq.), part F of title IV of 
the Social Security Act (42 U.S.C. 681 et seq.) (authorizing the Job 
Opportunity Basic Skills Training Program), the Goals 2000: Educate 
America Act, the Individuals with Disabilities Education Act (20 U.S.C. 
1400 et seq.), the Job Training Partnership Act (29 U.S.C. 1501 et 
seq.), the National Apprenticeship Act (29 U.S.C. 50 et seq.), the 
Rehabilitation Act of 1973 (29 U.S.C. 701 et seq.), and the National 
and Community Service Act of 1990 (42 U.S.C. 12501 et seq.);
    (5) Describe the State's strategy for providing training for 
teachers, employers, mentors, counselors, and other parties involved in 
the State's School-to-Work Opportunities System;
    (6) Describe the resources, including private sector resources, the 
State intends to employ in maintaining the State's School-to-Work 
Opportunities system when Federal School-to-Work Opportunities funds 
are no longer available;
    (7) Describe how the State will ensure effective and meaningful 
opportunities for all students to participate in School-to-Work 
Opportunities programs;
    (8) Describe the goals of the State and the methods the State will 
use, such as awareness and outreach, to ensure opportunities for young 
women to participate in School-to-Work Opportunities programs in a 
manner that leads to employment in high-performance, high-paying jobs, 
including non-traditional employment;
    (9) Describe how the State will ensure opportunities for low-
achieving students, students with disabilities, and former students who 
have dropped out of school to participate in School-to-Work 
Opportunities programs in a manner that leads to employment in high-
performance, high-paying jobs;
    (10) Describe the State's process for assessing the skills and 
knowledge required in career majors, and awarding skill certificates 
that take into account the work of the proposed National Skill 
Standards Board and the criteria established under the Goals 2000: 
Educate America Act;
    (11) Describe the performance standards that the State intends to 
meet;
    (12) Designate a fiscal agent to receive and be accountable for 
School-to-Work Opportunities funds awarded under the program; and
    (13) Describe how the State will stimulate and support local 
School-to-Work Opportunities programs that meet the requirements of 
this notice and how the State's system will be expanded over time to 
cover all geographic areas in the State, including those with high 
concentrations of poor and disadvantaged youth.

General Program Requirements

    A School-to-Work Opportunities program under this priority must 
include the following common features and basic program components:
    (a) The basis of the School-to-Work Opportunities system is--
    (1) The integration of work-based learning and school-based 
learning, that provides students, to the extent practicable, with broad 
instruction in all aspects of the industries students are preparing to 
enter;
    (2) The integration of occupational and academic learning; and
    (3) The linking of secondary and postsecondary education.
    (b) School-to-Work Opportunities programs will result in students 
attaining--
    (1) A high school diploma, or its equivalent;
    (2) A certificate or diploma recognizing successful completion of 
one or two years of postsecondary education, if appropriate; and
    (3) A skill certificate.
    (c) School-to-Work Opportunities programs must incorporate three 
basic program components:
    (1) Work-Based Learning, that includes--
     A planned program of job training and work experiences, 
including pre-employment and employment skills to be mastered at 
progressively higher levels, that are relevant to a student's career 
major and lead to the award of a skill certificate;
     Paid work experience;
     Workplace mentoring;
     Instruction in general workplace competencies.
    (2) School-Based Learning, that includes--
     Career awareness and career exploration and counseling 
(beginning at the earliest possible age) in order to help students who 
may be interested to identify, and select or reconsider, their 
interests, goals, and career majors, including those options that may 
not be traditional for their gender, race or ethnicity;
     Initial selection by interested students of a career major 
not later than the beginning of the 11th grade;
     A program of study designed to meet the same challenging 
academic standards developed by the State for all students including, 
where applicable, standards established under the Goals 2000: Educate 
America Act, and to meet the requirements necessary for a student to 
earn a skill certificate; and
     Regularly scheduled evaluations to identify academic 
strengths and weaknesses, academic progress, workplace knowledge and 
goals of students and the need for additional learning opportunities to 
master core academic and vocational skills.
    (3) Connecting Activities, that include--
     Matching students with employers' work-based learning 
opportunities;
     Serving as a liaison among the employer, school, teacher, 
parent, and student and, if appropriate, other community partners;
     Providing technical assistance and services to employers, 
including small and medium-sized businesses, and others, in designing 
work-based learning components and counseling and case management 
services, and in training teachers, workplace mentors, and counselors;
     Providing assistance to students who have completed the 
program in finding an appropriate job, continuing their education, or 
entering into an additional training program;
     Providing assistance to schools and employers to integrate 
school-based and work-based learning and integrate academic and 
occupational learning;
     Collecting and analyzing information regarding post-
program outcomes of students who participate in the School-to-Work 
Opportunities program which may include, information on gender, race, 
ethnicity, socio-economic background, limited- English proficiency, and 
disability; and
     Linking youth development activities under the School-to-
Work Opportunities program with employer and industry strategies for 
upgrading the skills of their workers.

Examples of Statewide Activities

    Funds awarded under this program shall be expended by the grantee 
only for activities undertaken to implement the State's School-to-Work 
Opportunities system, which may include--
    (a) Recruiting and providing assistance to employers to provide 
work-based learning for students;
    (b) Conducting outreach activities to promote and support 
collaboration in School-to-Work Opportunities programs by businesses, 
labor organizations, and other organizations, including stimulating the 
development of partnerships in poor communities;
    (c) Providing training for teachers, employers, workplace mentors, 
counselors, related services personnel, and others;
    (d) Providing labor market information to local partnerships that 
is useful in determining which high-skill, high-wage occupations are in 
demand;
    (e) Designing or adapting model curricula that can be used to 
integrate academic and vocational learning, school-based and work-based 
learning, and secondary and postsecondary education;
    (f) Designing or adapting model work-based learning programs and 
identifying best practices;
    (g) Conducting outreach activities and providing technical 
assistance to other States that are developing or implementing School-
to-Work Opportunities systems; and
    (h) Working with localities to develop strategies to recruit and 
retain all students in School-to-Work Opportunities programs, including 
those from a broad range of backgrounds and circumstances.

Allocation of Funds to Local Partnerships

    A grantee under this priority must award subgrants to local 
partnerships in carrying out activities under the School-to-Work 
Opportunities program, according to criteria established by the 
grantee. Subgrants to local partnerships shall total no less than 65 
percent of the sums awarded to each State in the first year, 75 percent 
of the sums awarded to each State in the second year, and 85 percent of 
such sums in each year thereafter.
    A partnership that seeks support in carrying out a local School-to-
Work Opportunities program shall submit an application to the State 
that--
    (a) Describes how the local program would include the basic School-
to-Work Opportunities program components and otherwise meet the 
requirements of this notice;
    (b) Sets forth measurable program goals and outcomes;
    (c) Describes the local strategies and timetables to provide 
School-to-Work Opportunities program opportunities for all students; 
and
    (d) Provides such other information as the State may require.

Examples of Activities for Local Partnerships

    Funds under this program that are used to support partnerships 
shall be expended only for activities undertaken to carry out School-
to-Work programs as provided for in this notice, and such activities 
may include--
    (a) Recruiting and providing assistance to employers, including 
small and medium-sized businesses, to provide the work-based learning 
components in the School-to-Work Opportunities program;
    (b) Establishing consortia of employers to support the School-to-
Work Opportunities program and provide access to jobs related to 
students' career majors;
    (c) Supporting or establishing intermediaries to perform the 
connecting activities described above in paragraph (c)(3) under 
``General Program Requirements'' and to provide assistance to students 
in obtaining jobs and further education and training;
    (d) Designing or adapting school curricula that can be used to 
integrate academic and vocational learning, school-based and work-based 
learning, and secondary and postsecondary education;
    (e) Providing training to work-based and school-based staff on new 
curricula, student assessments, student guidance, and feedback to the 
school regarding student performance;
    (f) Providing career exploration and awareness services, beginning 
at the earliest possible age, including counseling and mentoring 
services, college awareness and other services to prepare students for 
the transition from school to work;
    (g) Establishing in schools participating in a School-to-Work 
Opportunities program a graduation assistance program to assist at-
risk, disabled, and low-achieving students in graduating from high 
school, enrolling in postsecondary education or training, and finding, 
maintaining, or advancing in jobs;
    (h) Conducting or obtaining an in-depth analysis of the local labor 
market and the generic and specific skill needs of employers to 
identify high-demand, high-wage careers to target;
    (i) Integrating work-based and school-based learning into existing 
job training programs for youth who have dropped out of school;
    (j) Establishing or expanding school-to-apprenticeship programs in 
cooperation with registered apprenticeship agencies and apprenticeship 
sponsors;
    (k) Assisting participating employers, including small- and medium-
size businesses, to identify and train workplace mentors and to develop 
work-based learning components;
    (l) Designing local strategies to provide adequate planning time 
and staff development activities for teachers, school counselors, and 
related services personnel;
    (m) Enhancing linkages between after school, weekend, and summer 
jobs, and opportunities for career exploration and school-based 
learning; and
    (n) Conducting outreach to all students in a manner that most 
appropriately meets their needs and the needs of their communities.

Safeguards

    The Secretaries apply the following safeguards to School-to-Work 
Opportunities programs funded under this priority:
    (a) No student shall displace any currently employed worker 
(including a partial displacement, such as a reduction in the hours of 
non-overtime work, wages, or employment benefits).
    (b) No School-to-Work Opportunities program shall impair existing 
contracts for services or collective bargaining agreements, except that 
no program under this priority that would be inconsistent with the 
terms of a collective bargaining agreement shall be undertaken without 
the written concurrence of the labor organization and employer 
concerned.
    (c) No student shall be employed or job opening filled--
    (1) When any other individual is on temporary layoff from the 
participating employer, with the clear possibility of recall, from the 
same or any substantially equivalent job; or
    (2) When the employer has terminated the employment of any regular 
employee or otherwise reduced its workforce with the intention of 
filling the vacancy so created with a student.
    (d) Students shall be provided with adequate and safe equipment and 
a safe and healthful workplace in conformity with all health, safety, 
and labor standards of Federal, State, and local law.
    (e) Nothing in this priority shall be construed so as to modify or 
affect any Federal or State law prohibiting discrimination on the basis 
of race, religion, color, ethnicity, national origin, gender, age, or 
disability.
    (f) Funds awarded under this priority shall not be expended for 
wages of students.
    (g) The grantee shall implement and maintain such other safeguards 
as the Secretaries may deem appropriate in order to ensure that School-
to-Work Opportunities participants are afforded adequate supervision by 
skilled adult workers, or, otherwise, to further the purposes of this 
program.
    An applicant must provide an assurance, in the application, that 
the foregoing safeguards will be implemented and maintained throughout 
all program activities.

Selection Criteria for Evaluating Applications

    Under the School-to-Work Opportunities Implementation Grant 
competition, the Secretaries will use the following selection criteria 
in evaluating applications. The Secretaries will evaluate applications 
using a two-phase review process. In the first phase of the review 
process, the Secretaries will use peer reviewers to evaluate 
applications using the selection criteria and the associated point 
values. In the second phase, review teams will visit high-ranking 
States to gain further information and further assess State plans. The 
second-phase review teams will use the criteria, but not necessarily 
the associated point values, in their information-gathering and 
assessment activities. Final funding decisions made by the Secretaries 
will be based on information gained during the site visits, the ranking 
of applications during the first-phase review, and such other factors 
as geographic balance and diversity of program approaches, 
replicability, sustainability, and innovation.
    (a) Comprehensive Statewide System. (25 points) Is the School-to-
Work Opportunities plan described in the application likely to produce 
systemic statewide change that will have substantial impact on the 
preparation of youth for a first job in a high-skill, high-wage career 
and in increasing their opportunities for further education? Does the 
plan provide information reflecting the needs of each local labor 
market area in the designated geographic areas of the State? Does the 
State propose a feasible plan for expanding the system to ensure that 
all geographic areas of the State, including communities with high 
concentrations of poor and disadvantaged youth, will have an 
opportunity to participate in School-to-Work Opportunities programs 
within a reasonable period of time? Is the process for assessing skills 
and issuing skill certificates likely to lead to portable credentials 
for students and are the skills adequately benchmarked to high quality 
standards such as those envisioned in the Goals 2000: Educate America 
Act? Does the State's process for assessing skills reflect the needs of 
high performance workplaces and meet the requirements of broad clusters 
of related occupations and industries, rather than those of individual 
jobs or occupations? Has the State described State and local 
performance standards that should lead to statewide systemic reform of 
secondary education?
    (b) Collaboration and Involvement of Key Partners. (25 points)
    (1) State collaboration: Is there a vision for implementing a 
statewide School-to-Work Opportunities system that is shared by the 
Governor; the State educational agency; the State agency officials 
responsible for job training and employment, economic development, and 
postsecondary education; and other appropriate officials? Does the plan 
substantially demonstrate sufficient commitment and specific 
involvement of these partners in the statewide implementation? Are the 
activities appropriate to the partners and likely to produce the 
desired changes in the way students are prepared for the future? Is 
there evidence that the State partners have the capacity to support the 
statewide implementation?
    (2) Involvement by key parties: Does the State plan include an 
effective and convincing strategy for obtaining the active and 
continued involvement of employers and other interested parties such as 
locally elected officials, secondary and postsecondary educational 
institutions or agencies, business associations, employees, labor 
organizations or associations thereof, teachers, students, parents, 
community-based organizations, rehabilitation agencies and 
organizations, registered apprenticeship agencies, and local vocational 
educational agencies in the implementation of statewide systems? Does 
the strategy recognize the interests of the key parties and utilize 
their strengths appropriately? Does the plan reflect the input of 
employers and other key parties?
    (c) Resources. (10 points) Is the plan for a comprehensive 
statewide School-to-Work Opportunities system adequately supported by 
other Federal, State, and local resources? Does the plan effectively 
integrate State and private education and training resources with other 
Federal education and training resources? Does the plan limit 
administrative costs in order to maximize the amounts spent on delivery 
of services to students enrolled in its School-to-Work Opportunities 
programs? Is there an effective long-term plan for maintaining the 
School-to-Work Opportunities system with resources other than Federal 
School-to-Work Opportunities funds?
    (d) Student Participation. (15 points) Does the plan propose 
realistic strategies and programs to ensure that ``all students,'' 
including young women, minorities, low-achieving students, students 
with disabilities, students with limited-English proficiency, 
academically talented students, and former students who have dropped 
out, have the opportunity to participate in School-to-Work 
Opportunities programs? Does the strategy recognize barriers to their 
participation and propose effective ways of overcoming them so that 
these students are prepared for high-skill, high-wage jobs including, 
for young women and minorities non-traditional employment?
    (e) Local Programs. (15 points) Does the plan include an effective 
strategy for supporting local School-to-Work Opportunities programs 
that integrate occupational and academic learning, integrate work-based 
and school-based learning, establish linkages between secondary and 
postsecondary education, include components for work-based learning, 
school-based learning and connecting activities, and result in the 
award of a high school diploma or its equivalent, a certificate or 
diploma recognizing successful completion of one or two years of 
postsecondary education (if appropriate), and a skill certificate? Have 
promising existing programs been considered for adaptation? Have new 
directions and approaches been planned to ensure that these programs 
meet the priority? Does the plan show evidence that local School-to-
Work Opportunities programs throughout the State, including those that 
have been funded by the Department of Education or the Department of 
Labor, are an effective part of a statewide School-to-Work 
Opportunities system?
    (f) Management Plan. (10 points) Does the entity submitting the 
application on behalf of the State have the capacity to manage the 
implementation of a comprehensive statewide School-to-Work 
Opportunities system? Does the State's management plan anticipate 
barriers to statewide implementation and include a system for 
addressing them as they arise? Does the management plan include a 
process for incorporating methods to improve or redesign the 
implementation system based on program outcomes, for example through an 
evaluation plan? Will the State's performance standards be applied to 
local partnerships and will the standards be used to evaluate and 
improve their outcomes? Are key personnel under the plan qualified to 
perform the required activities, particularly to maintain the essential 
partnerships at the State level in a manner sufficient to implement the 
plan? Will Federal funds under the School-to-Work Opportunities Program 
grant be used to support partnerships that seek to carry out local 
School-to-Work Opportunities programs?

Other Factors

    In addition to considering the factor of geographic distribution 
authorized under 34 CFR 426.25 of the Cooperative Demonstration program 
regulations, prior to making final funding decisions, the Secretaries 
also will consider as a factor the diversity of approaches to School-
to-Work Opportunities proposed by each applicant.

Intergovernmental Review

    This program is subject to the requirements of Executive Order 
12372 and the regulations in 34 CFR part 79. The objective of the 
Executive order is to foster an intergovernmental partnership and a 
strengthened federalism by relying on processes developed by State and 
local governments for coordination and review of proposed Federal 
financial assistance.
    In accordance with the order, this document is intended to provide 
early notification of the Department's specific plans and actions for 
this program.
    Applicable Program Regulations: 34 CFR parts 400 and 426.

    Program Authority: 20 U.S.C. 2420a.

(Catalog of Federal Domestic Assistance Number 84.199-H Cooperative 
Demonstration Program)

    Dated: January 25, 1994.
Richard W. Riley,
Secretary of Education.
Robert B. Reich,
Secretary of Labor.

Appendix--Analysis of Comments and Changes

General

    Comment: One commenter noted that Congress is currently debating 
the exact requirements for programs under the proposed School-to-Work 
Opportunities bill and expressed the belief that States are not 
immediately prepared to implement Statewide plans and systems. The 
commenter suggested that it would be preferable to extend the comment 
period for this notice until after Congress has agreed to the statutory 
program requirements. The commenter suggested that if the Departments 
choose to award implementation grants prior to the enactment of School-
to-Work Opportunities legislation, they would have the authority to 
include provisions not contained in the original Administration bill 
nor, indeed, in the House or the Senate versions, so long as these 
provisions are consistent with the broad provisions for the Cooperative 
Demonstration Program authorized under section 420A of the Perkins Act, 
and 34 CFR 426.4, under which the funds for this competition were 
appropriated.
    Discussion: The Secretaries do not agree that the comment period 
should be extended until the School-to-Work Opportunities bill is 
enacted into law by Congress. Indicative of Congressional intent to 
allow States and localities to begin establishing School-to-Work 
Opportunities systems, Congress has appropriated funds under existing 
authority for this fiscal year 1994 competition. The Secretaries wish 
to award grants as soon as possible after July 1, 1994, when the funds 
become available, so that the States that compete successfully for 
those funds may have School-to-Work Opportunities systems operating in 
the 1994-95 school year. Waiting until enactment to publish a notice 
inviting applications would inevitably result in significant delays in 
both awarding funds and initiating programs and activities. At the same 
time, however, the Secretaries want to make certain that, to the 
greatest extent practicable, this priority reflects the most current 
Congressional action to date on the pending legislation. Accordingly, 
where provisions of the House and Senate bills are identical and differ 
from the provisions in the proposed notice, and where the House and 
Senate modifications are consistent with relevant existing authorities, 
the Secretaries have reflected those modifications in this final 
notice.
    Changes: Changes have been made in the notice to reflect House and 
Senate modifications to the proposed School-to-Work Opportunities 
legislation, where those changes are consistent with relevant existing 
statutory authorities.
    Comment: One commenter stated that, because the Federal Government 
already carries out the function of career education through the 
National Occupational Information Coordinating Committee, the 
Secretaries should add a fourth Federal role to the three already 
delineated in the ``Background'' section of the notice, ``to assist 
States in the provision of accurate and timely occupational and career 
development information for purposes of program planning, career 
guidance and counseling, and individual career exploration, choice and 
educational planning.''
    Discussion: The Federal role that is delineated in the 
``Background'' section of the October 14, 1993 notice is a broad 
characterization of the Federal role envisioned by the Secretaries. The 
``Background'' section is not meant to delineate each of the ways in 
which the Federal Government might assist States or localities to 
implement school-to-work systems. Counseling and integrating existing 
Federal, State, and local programs into comprehensive School-to-Work 
Opportunities systems is clearly of vital importance to the national 
School-to-Work Opportunities framework and are embodied in the criteria 
in this notice as well as in the pending legislation. Although it is 
not the Secretaries' intent to recount all possible Federal roles here, 
the Secretaries have added reference to a fourth Federal role, that of 
creating a national School-to-Work Opportunities framework through 
common core criteria and national standards. The Secretaries believe 
that the Federal role referred to by the commenter is implicit in this 
notice.
    Changes: Reference to an additional Federal role, that of creating 
a national School-to-Work Opportunities framework, has been added to 
``Background'' section of this notice.
    Comment: One commenter thought that the final priority should give 
preference to, and thereby require applications to identify a 
significant portion of the funds available for local systems for use in 
high poverty areas.
    Discussion: The competition covered by this notice is for State 
grants only. From grants received under this competition, grantees will 
distribute a substantial amount of funds to localities, including high 
poverty areas. Each State must demonstrate in its plan how it will 
ensure opportunities for ``all students'' to participate in the 
program. In addition, each State will be required to describe how its 
School-to-Work Opportunities system will be expanded to cover all 
geographic areas, including high poverty areas. The Departments will 
soon announce a separate direct grant program for local projects 
located in high poverty areas.
    Changes: None.
    Comment: One commenter believed that it was unclear from the notice 
whether there are clear vehicles for the Federal Government to help 
States and localities learn from each other and from the experience of 
international competitors, and to build a knowledge base of effective 
school-to-work models. Therefore, the commenter suggested that the 
notice be modified to include a separate grant program or a contract to 
support the Federal Government in achieving these roles.
    Discussion: This notice relates only to the School-to-Work 
Opportunities State grants competition. However, other funds will be 
available under the fiscal year 1994 appropriation for Federal level 
activities, such as technical assistance and research and development, 
that will help States and localities learn from each other and from the 
experiences of our international competitors, and that will help States 
build a knowledge base of effective school-to-work models. The 
Secretaries do not envision one separate grant or contract for 
achieving these purposes, but plan to utilize the broad range of 
vehicles available to them.
    Changes: None.
    Comment: One commenter noted that very little institutional 
structure is available in the United States that could manage the 
partnerships anticipated, and suggested awarding a separate seed grant 
to a local body not politically tied to any one of the stakeholders for 
this purpose.
    Discussion: The Secretaries believe that States and local 
communities can best determine how to form and govern the partnerships 
required under this program. A local partnership can determine for 
itself which entity in that community is best equipped to manage the 
partnership. Thus, the Secretaries see no need for the separate direct 
Federal grants recommended by the commenter.
    Changes: None.
    Comment: One commenter noted that certificates and credentials in 
the United States are linked to limited, very defined jobs, such as 
``radiology,'' and not to sets of skills that integrate knowledge 
across an industry. The commenter suggested that the States will need 
to overhaul their current approach to certification and credentialing 
if this definition is to be realized.
    Discussion: It is the Secretaries' intent that States design 
School-to-Work Opportunities programs of high quality that will prepare 
students to become part of a high-performance workforce and that will 
lead to skill certificates as one of the outcomes of participation. 
Until there is a system of national skill standards, States are 
encouraged to apply the highest standards and certifications available. 
During this period, the Departments will be assisting States in 
identifying sources and means by which to access existing high quality, 
industry-recognized standards and accompanying assessment tools, as 
well as assisting States to collaborate effectively with each other 
toward the development of high quality skill standards. Once the 
National Skill Standards Board begins its work, and even before there 
are skill standards actually endorsed by the Board, States will be 
required to take the work of the Board into consideration in their 
development of standards for skill certificates, as is likely to be 
required under the proposed School-to-Work Opportunities legislation. 
This is intended to facilitate the development of national, portable 
credentials and to avoid unnecessary duplication and overlap.
    Changes: None.

Subgrants to Local Partnerships

    Comment: One commenter recommended that ``currently applicable 
Federal laws'' that would allow States to fund local partnerships 
should be specified in the final notice. The commenter noted that 
without this specific information, States would be unable to award 
grant funds to local partnerships.
    Discussion: Authority for States to award subgrants to local 
partnerships is now contained in the 1994 Department of Education 
Appropriation Act. Accordingly, the notice clearly provides that States 
receiving School-to-Work Opportunities implementation grants must 
distribute to local partnerships 65 percent of the amounts received in 
the first year, 75 percent of the amount received in the second year, 
and 85 percent of the amount received in each year thereafter.
    Changes: The notice has been modified to reflect the subgrant award 
authority provided in the 1994 Department of Education Appropriation 
Act.

Peer Review

    Comment: Two commenters made suggestions regarding peer reviewers 
for this competition. One commenter said that the notice should require 
peer reviewers to represent all the entities that could be members of 
partnerships at the State level for development and administration of 
School-to-Work Opportunities systems, including representatives from 
secondary education, postsecondary education, employment, job training, 
and economic development. The second commenter recommended that the 
Secretaries include either individuals with disabilities or members of 
their families on the review panels.
    Discussion: The Secretaries wish to assure the commenters that they 
plan to select peer reviewers carefully, based on experience, 
education, training, and expertise in areas relevant to School-to-Work 
Opportunities systems, and will seek to have as broad a representation 
as possible on the review panels. However, specific requirements or 
criteria for the selection of peer reviewers is outside the purpose and 
scope of this notice.
    Changes: None.

Definitions--``All Students''

    Comment: One commenter expressed confusion about the meaning of the 
term ``all students,'' as defined in the October 14, 1993 notice. The 
commenter recommended that, if the Secretaries intended the term to 
mean all students rather than a representative sub-sample of students, 
the definition should be clarified by using the phrase ``all students 
from the broad range of backgrounds'' in lieu of the phrase ``students 
from the broad range of backgrounds.''
    Discussion: The Secretaries intend the definition of ``all 
students'' to be broadly inclusive of diverse groups within the 
Nation's student population, including youth who have dropped out of 
school. The definition in the notice should not be interpreted as 
meaning a representative sub-sample of students.
    Change: None.
    Comment: One commenter noted that the term ``all students'' does 
not appear to include out-of-school youth. The commenter stated that 
excluding dropouts from the definition will result in the exclusion of 
millions of young people from eligibility to participate in the School-
to-Work Opportunities program, including, for example, over one-third 
of Hispanic youth of high school age.
    Discussion: The Secretaries agree with the commenter that the 
definition of the term ``All students'' should include youth who are 
high school dropouts. Similarly, the Secretaries anticipate that, in 
the final version of the School-to-Work Opportunities legislation, this 
term will be defined as including students who have dropped out of 
school.
    Changes: The definition of the term ``All students'' has been 
changed to include students who have dropped out of school.
    Comment: Two commenters expressed concern with the extent to which 
States would be required to provide for the participation of students 
from disadvantaged backgrounds in their School-to-Work Opportunities 
programs. One commenter expressed the view that if ``all students'' are 
intended to be successful in the School-to-Work Opportunities 
initiative, the notice should require or acknowledge the need for 
considerably more effort and resources to be devoted to female students 
and to students from disadvantaged backgrounds. Another commenter felt 
that the notice should include language emphasizing inclusive projects, 
that is, that the school-to-work needs of all students should be 
addressed, not simply the needs of mainstream children without special 
needs.
    Discussion: The definition of the term ``All students'' in this 
notice includes a number of population groups with special needs. Among 
these are disadvantaged students, students with disabilities, students 
with limited-English proficiency, and former students who have dropped 
out of school. Moreover, under the ``Student Participation'' selection 
criterion, reviewers will assess the extent to which States propose 
realistic strategies and programs to demonstrate that ``all students,'' 
including young women, minorities, and low achieving students, have the 
opportunity to participate in the State's School-to-Work Opportunities 
program. The notice also requires that State plans address how States 
will provide opportunities for all students to participate in School-
to-Work Opportunities programs. The Secretaries agree, however, that an 
additional question in the selection criteria would help evaluators 
assess the extent to which States have also addressed the needs of 
students from communities with high concentrations of poor and 
disadvantaged youth. Similarly, the Secretaries have concluded that the 
priority should include a specific reference to communities with high 
concentrations of poor and disadvantaged youth. Thus, the Secretaries 
have revised the notice to require States to indicate specifically in 
their plans how all students, including women, minorities, low 
achieving students, and students from communities with high 
concentrations of poor and disadvantaged youth, will have an 
opportunity to participate in each State's proposed School-to-Work 
Opportunities program. The Secretaries have also revised the selection 
criterion to consider whether States propose feasible plans to include 
communities with high concentrations of poor and disadvantaged youth in 
the system.
    Changes: Paragraph (b)(13) of the priority and the ``Comprehensive 
Statewide System'' selection criterion have been modified to require 
States to describe in their plans how the States' proposed School-to-
Work Opportunities systems will address the needs of students from 
communities with high concentrations of poor and disadvantaged youth.
    Comment: One commenter expressed the view that the current School-
to-Work Opportunities initiative deals only with students who are not 
likely to enroll in college. The commenter suggested that, in order to 
avoid tracking, clearly articulated 2+1, 2+2, and 2+2+2 programs would 
be preferable in that they would allow students to exercise a variety 
of options in both employment and educational environments.
    Discussion: The School-to-Work Opportunities program is not 
intended to be limited to only certain categories of students. The 
definition of ``all students'' specifically includes students from a 
broad range of backgrounds and circumstances, including academically 
talented students. The notice establishes that career majors would 
typically include two years of secondary school as well as one or two 
years of postsecondary education. And, as part of their participation 
in a School-to-Work Opportunities program, students who are completing 
their first or second years at the postsecondary level would be 
prepared to take advantage of options in employment and education, 
including enrollment in a college or university bestowing a four-year 
degree. However, the Secretaries agree with the commenter that the 
definition should be revised to clarify that admission into such a 
college or university is just one of the options available to 
participating students to which a career major may lead.
    Changes: Paragraph (e) of the definition of ``Career major'' has 
been revised by adding the clause ``or admission into a degree-granting 
college or university.''

Definitions--All Aspects of an Industry (Previously ``Elements of the 
Industry'')

    Comment: Two commenters raised questions relative to the definition 
of ``Elements of the industry,'' as used in the proposed priority 
notice. One commenter thought that the proposed definition of 
``Elements of the industry'' did not promote the kind of thorough and 
challenging understanding of all aspects of an industry that are 
necessary for the School-to-Work Opportunities initiative to be 
successful in transforming the future American labor force. Instead, 
the commenter stated a preference for the language in the Carl D. 
Perkins Vocational and Applied Technology Education Act that requires 
students to be provided with an understanding of ``all aspects of an 
industry.'' The second commenter believed that the term ``industry'' 
would be poorly understood and that the term should be defined as a 
collection of employers who share common requirements for human and 
physical capital, such as the aerospace industry, etc.
    Discussion: The Secretaries agree that it is preferable for the 
term utilized in this notice to be consistent with the term utilized in 
the Carl D. Perkins Vocational and Applied Technology Education Act. 
Moreover, the term ``All aspects of the industry'' also appears in both 
the Senate and House bills of the School-to Work Opportunities bills 
currently under consideration by Congress. Therefore, the Secretaries 
have eliminated the term ``Elements of the industry'' from the notice, 
and have substituted the term ``All aspects of the industry.'' However, 
the Secretaries feel that the term ``industry'' is clear in the context 
of this definition, and need not be further defined in this notice.
    Changes: The term ``Elements of the industry'' has been replaced by 
the term ``All aspects of the industry'' for the purpose of achieving 
consistency with the proposed School-to-Work Opportunities legislation, 
as well as with the Carl D. Perkins Vocational and Applied Technology 
Education Act. Likewise, the definition of the term ``all elements of 
the industry'' has been replaced with the definition of ``all aspects 
of the industry'' from the regulations implementing the Perkins Act, at 
34 CFR 400.4(b).

Definitions--Career Major

    Comment: Two commenters expressed the view that, when coupled with 
the examples of local partnership activities contained in the notice, 
the proposed definition of the term ``Career major'' suggests that the 
School-to-Work Opportunities initiative will not recognize a high 
school equivalency diploma as being equivalent to the attainment of an 
actual high school diploma. These commenters recommended that the 
definition of a ``Career major'' be amended to better accommodate out-
of-school youth by including both passage of a high school equivalency 
test and the high school diploma, as acceptable outcomes of 
participation in School-to-Work Opportunities programs.
    Discussion: The Secretaries agree with the commenters that, in 
part, the attainment of an equivalency diploma by a former student who 
has participated in, and completed, a School-to-Work Opportunities 
program, would be an acceptable outcome of such participation.
    Changes: The definition of the term ``Career major'' has been 
modified to include an ``equivalent'' certificate. (Parallel changes 
have been made in the ``General Program Requirements'' section of the 
notice and the ``Local Programs'' selection criterion.)
    Comment: One commenter stated that, while a four-year degree is not 
the primary focus or goal of the School-to-Work Opportunities 
initiative, it should be considered an appropriate outcome of 
participation in a School-to-Work Opportunities program. The commenter 
felt that course work should be sufficiently rigorous and linked to 
higher education academic requirements so a student could enter into a 
four-year academic program following participation in the program. This 
commenter suggested that the term, ``or enrollment in a Bachelor's 
degree program'' be added to the end of the last sentence in the 
definition of the term ``career major.''
    Discussion: The Secretaries agree with the reasoning provided by 
the commenter, as discussed above.
    Changes: Paragraph (e) of the definition of the term ``career 
major'' has been revised by adding the clause ``or admission into a 
degree-granting college or university'' so as to clarify that, among 
other things, completion of a career major may result in admission into 
a degree-granting college or university.
    Comment: One commenter stated that the proposed definition of a 
``career major'' included criteria that would result in an automatic 
barrier preventing many students with disabilities from benefitting 
from a School-to-Work Opportunities program. This commenter felt that, 
in most school systems, students participating in special education 
programs continue to receive certificates in lieu of a high school 
diploma and that one or two additional years of training past high 
school should be an acceptable outcome for many of these learners in 
lieu of one or two years of postsecondary education. The commenter 
recommended that the definition of the term ``career major'' be revised 
in specific ways to accommodate and encourage the participation of 
special education students.
    Discussion: The Secretaries do not intend to discourage the 
participation of students with disabilities in State School-to-Work 
Opportunities programs. Indeed, the School-to-Work Opportunities 
initiative is intended to serve all students, as has already been 
discussed. Moreover, the Secretaries agree with the commenter that many 
States already provide equivalent diplomas or certificates to disabled 
students. Accordingly, the Secretaries intend to include within the 
term ``equivalent,'' which has been added to the definition of the term 
``Career major,'' certificates provided by States to students with 
disabilities, that are considered to be equivalent to high school 
diplomas.
    Changes: The definition of ``Career major'' has been revised to 
include reference to the ``equivalent'' of a high school diploma.
    Comment: One commenter felt that two years of secondary school and 
one or two years of post-secondary education would be too great a time 
commitment for many disadvantaged youth, particularly dropout youth. In 
the opinion of the commenter, disadvantaged youth with children or 
disadvantaged youth supporting themselves financially, necessarily 
require a faster route to employment. Accordingly, the commenter 
suggested that ``one plus one,'' or a condensed one year program, would 
better serve their needs.
    Discussion: The Secretaries believe that directing disadvantaged 
youth to abbreviated versions of the high quality programs being 
provided to all other students would serve only to short-change the 
disadvantaged students since abbreviated programs would fail to provide 
participants with the qualifications needed to obtain high-skill, high-
wage employment. A high school diploma and, often, one or two years of 
further education or training are required for students to obtain the 
kinds of high-skill, high-wage employment envisioned by the School-to-
Work Opportunities initiative. It is important to note also that paid 
work experience--which is a basic program requirement of the School-to-
Work Opportunities program's work-based learning component--can also 
serve to provide some amount of income to participating disadvantaged 
students. The students are also eligible for additional services under 
other programs such as the Job Training Partnership Act. Moreover, 
under this program, States and local partnerships retain the 
flexibility to develop innovative supportive services for disadvantaged 
students participating in School-to-Work Opportunities programs geared 
toward further assisting them to meet their financial and other needs.
    Changes: None.

Definitions--Partnership

    Comment: Four commenters believed that the participation of 
community-based organizations (CBOs) should be required in program 
planning, implementation, and evaluation and, that to accomplish this, 
the term ``Partnership'' should be redefined to ensure that CBOs are 
not left out due to a definition that appears to make their involvement 
optional. A fifth commenter recommended that the definition of 
``Partnership'' be modified to require the participation of ``teachers 
and related services personnel'' as a part of each partnership. The 
commenter believed that this was necessary to encourage the 
participation of certain individuals (including rehabilitation 
counselors, school counselors, psychologists, speech and language 
pathologists, audiologists, and social workers), who the commenter 
believes are necessary to the successful participation of students with 
disabilities in the School-to-Work Opportunities program.
    Discussion: The Secretaries agree with the commenters that CBOs 
will make important contributions to program planning, implementation, 
and evaluation of School-to-Work Opportunities programs and encourage 
partnerships to include them. Indeed, the Secretaries believe that most 
localities will choose to include CBOs because of the value that they 
are likely to bring to local partnerships. The Secretaries also believe 
that teachers and related services personnel are likely to be helpful 
as members of partnerships, and encourage localities to include them to 
the extent possible. However, the Secretaries are opposed to requiring 
the participation in all partnerships of either CBOs or teachers and 
related services personnel, and continue to believe that localities 
should be allowed to determine the membership in partnerships of 
entities or groups outside of those whose membership is specifically 
mandated through the notice's definition of the term ``Partnership.''
    Changes: None.
    Comment: One commenter felt that the definition of the term 
``Partnership'' appeared to call for the establishment of a separate 
local entity instead of a simple collaboration of entities and believed 
this to be an unnecessary bureaucratic layer.
    Discussion: Within the parameters and requirements specified in the 
notice, States and localities will determine whether partnerships are 
to be separate local entities or whether they are to consist of simple 
collaborations of existing entities or groups. The Secretaries do not 
intend the notice to require another bureaucratic layer or entity.
    Changes: None.

Definitions--Skill Certificate

    Comment: One commenter believed that the definition of the term 
``Skill certificate'' would impose a barrier for students with 
disabilities and would encourage their exclusion from States' School-
to-Work Opportunities programs. The commenter suggested that the 
definition be changed to read, ``a portable, industry-recognized 
credential issued by a program that certifies that a student has 
mastered skills at levels that, to the extent feasible, are at least as 
challenging as the standards endorsed by the National Skill Standards 
Board.''
    Discussion: As provided for in paragraph (b)(8) of the priority, 
under the School-to-Work Opportunities program, States are required to 
describe in their plans how they will ensure that students with 
disabilities will have opportunities to participate in the States' 
School-to-Work Opportunities programs. Under the ``Student 
Participation'' selection criterion, States are required to propose 
realistic strategies and programs to ensure that all students, 
including students with disabilities, have opportunities to participate 
in their States' School-to-Work Opportunities programs. The clause 
``ensuring opportunities to participate'' is intended to include 
opportunities to achieve program outcomes, including a skill 
certificate. While it is very important that individuals with 
disabilities be provided with the necessary support to ensure that they 
have the opportunity to participate, the Secretaries do not see the 
need to modify the definition of the term ``Skill certificate'' to 
provide for different skill levels for students with disabilities, than 
those provided for students without disabilities.
    Changes: None.

Definitions--State

    Comments: Five commenters noted that the term ``State'' is not 
defined in the notice. They suggested that, to avoid confusion, the 
term ``State'' should be defined as ``each of the several States, the 
District of Columbia, and the Commonwealth of Puerto Rico.''
    Discussion: The applicable definition of the term ``State'' is 
contained in section 521(33) of the Carl D. Perkins Vocational and 
Applied Technology Education Act, as implemented by Sec. 400.4(b) of 
the Perkins regulations.
    Changes: None.

Definitions--Workplace Mentor

    Changes: None.
    Comment: One commenter suggested that the workplace mentor was a 
critical link within the School-to-Work Opportunities program and was 
likely to require special training in order to fulfill this role 
effectively. The commenter viewed the workplace mentor as being a 
pedagogue with technical knowledge of the employment areas of interest 
to the students participating in the program. The commenter felt that 
greater consideration should be given under this program to training of 
workplace mentors and that this could best be achieved under a separate 
grant program.
    Discussion: Under this priority, State and local partnerships may 
utilize implementation grant funds to train workplace mentors to ensure 
that they are knowledgeable in the employment areas that School-to-Work 
Opportunities students are engaged in and to ensure that the mentors 
have the necessary knowledge of the work-based curriculum as well as 
other program policies and practices. Because the Secretaries believe 
that partnerships should be able to customize programs to meet the 
needs of local communities, including those of employers and students, 
they do not believe that a separate grant program is necessary to 
providing the proper training for workplace mentors.
    Changes: None.
    Comment: One commenter believed the definition of the term 
``Workplace mentor'' should be changed to include ``other individuals 
approved by the employer'' to be included as a workplace mentor so that 
individuals such as special educators, vocational rehabilitation 
counselors, job coaches, and work-study coordinators could serve in 
this capacity for youth with disabilities.
    Discussion: The Secretaries agree with the commenter's suggestion.
    Changes: The definition of ``Workplace mentor'' has been modified 
to include ``another individual approved by the employer.''

Priority--General

    Comments: Two commenters suggested that the Secretaries consider 
awarding School-to-Work Opportunities grants on a priority basis to: 
(1) Areas with high levels of unemployment, (2) areas that are impacted 
by military base closures, and (3) areas that are experiencing cutbacks 
in defense spending or conversions from defense manufacturing. One of 
the commenters also suggested that the Secretaries consider awarding 
grants under this competition based on priorities addressing new and 
emerging technologies and displaying ``complete vertical integration 
from start to partnering and productive employment placement.'' 
Similarly, the second commenter felt that priority should be extended 
to areas of economic need that can greatly benefit from additional 
coordinated funding such as that available under the National and 
Community Service Act. A third commenter felt that priority should be 
given to communities with high concentrations of poor and disadvantaged 
youth.
    Discussion: The purpose of this award is to provide funds to States 
to develop statewide School-to-Work Opportunities systems. The State 
plan must describe how the State will stimulate and support local 
School-to-Work Opportunities programs and how the State system will be 
expanded over time to cover all geographic areas in the State including 
those with high concentrations of poor and disadvantaged youth. States 
must also distribute a significant portion of their grant funds to 
local partnerships (65 percent in the first year, 75 percent in the 
second year, and 85 percent in the third year.) Within this context, 
States and localities have the flexibility to determine those areas 
that should receive priority in the establishment of statewide systems 
and for receipt of funds. While the Secretaries recognize the value of 
directing School-to-Work Opportunities funds to all of the areas named 
by the commenters, the Secretaries are opposed to mandating to States 
that these areas receive funds on a priority basis. Although they have 
not established a priority for such communities, in response to the 
third commenter's concerns about communities with high concentrations 
of poor and disadvantaged youth, the Secretaries have made a change.
    Changes: The notice has been modified to include the requirement in 
both paragraph (b)(13) of the priority and in the ``Comprehensive 
Statewide System'' selection criterion that States provide 
opportunities for participation in their School-to-Work Opportunities 
programs by students in all parts of each State, including communities 
with high concentrations of poor and disadvantaged youth.

Priority--Eligibility and Absolute Preference to State Applications

    Comment: One commenter stated that making States responsible for 
School-to-Work Opportunities programs made sense for most populations 
but not necessarily for migrant or seasonal farmworkers. The commenter 
felt that what he referred to as ``State-run initiatives'' sometimes 
fail to include services for these populations since they are often 
considered to be a national population. In the commenter's view, even 
where States are aware that farmworkers live within their boundaries, 
States often do not have the special expertise needed to provide these 
populations with services, or may not be able to serve the full range 
of the farmworker population. The commenter suggested that the 
Secretaries encourage States to take the unique needs of farmworker 
youth into account as States develop their comprehensive statewide 
School-to-Work Opportunities plans.
    Discussion: Secondary students from farmworker and migrant 
populations are included within the definition of ``all students.'' 
``All students'' is defined to mean ``students from a broad range of 
backgrounds and circumstances, including disadvantaged students, 
students of diverse racial, ethnic, and cultural backgrounds * * * 
students with limited-English proficiency * * * .'' The Secretaries 
expect migrant and seasonal farmworker youth to be served under the 
School-to-Work Opportunities Program. In further response to the 
concerns of the commenter, the Secretaries strongly encourage States 
with migrant and seasonal farmworker populations, to take the full 
range of needs of migrant and seasonal farmworker youth into account in 
developing their plans.
    Changes: None.
    Comment: One commenter stated that among the applications that 
should be given absolute preference under this competition are 
applications that describe: (1) How occupational and career development 
information available through State Occupational Information 
Coordinating Committees (SOICCs) and State Employment Security Labor 
Market Information Units will be used for planning, guidance, and 
career exploration purposes; and (2) the kinds of career development 
assistance that will be made available to students, including guidance 
and counseling, occupational and career information, portfolios, and 
other educational planning tools, and the manner in which parents and 
teachers will be brought into the career development aspects of the 
School-to-Work Opportunities program.
    Discussion: With regard to SOICCs and State Employment Security 
Labor Market Information Units, the Secretaries agree that these could 
be important sources of information for many States. However, it is 
thought preferable to allow States the flexibility to determine what 
are the best sources of information for their specific needs, as well 
as the best methods of obtaining information important to their 
programs. In response to the commenter's second point, the Secretaries 
note that, in paragraph (b)(3) of the priority, States must describe 
their ``procedure for obtaining the active and continued involvement in 
the statewide School-to-Work Opportunities system of * * * teachers, 
students, and parents * * *.'' The Secretaries have concluded that it 
is preferable to allow each State the flexibility to determine both the 
specific kinds of career development assistance that will be made 
available to students and the specific manner in which parents and 
teachers will be included in the career development aspects of the 
School-to-Work Opportunities program.
    Changes: None.
    Comment: One commenter was of the opinion that community colleges 
are in a good position to assist in linking secondary and postsecondary 
institutions so as to improve the quality of what the commenter 
referred to as co-op education programs. The commenter suggested that 
community colleges should have the opportunity to apply for grants 
under this program or to be designated as fiscal agents. Further, the 
commenter suggested that, given the opportunity, community colleges 
could serve effectively as centralized ``School-to-Work Program 
Centers'' and could develop consortium arrangements between high 
schools and employers.
    Discussion: Under this competition, grants will be made to States 
and each State will designate a fiscal agent. States, in turn, will 
award subgrants to local partnerships that must include employers, 
public secondary and postsecondary educational institutions or 
agencies, and labor organizations or employee representatives. As 
public postsecondary educational institutions, many community colleges 
will qualify to participate in partnerships. Community colleges are 
expected to play an important and active role in School-to-Work 
Opportunities programs. The matter of which entity will serve as grant 
recipient or fiscal agent at the State or local level will be decided 
by States and local partnerships.
    Changes: None.

Priority--Comprehensive Statewide System

    Comment: One commenter believed that one goal of a School-to-Work 
Opportunities system is not only to prepare youth for existing jobs but 
also to enable them to gain access to growing sectors of the economy 
likely to affect future markets. In the view of the commenter, States 
should be encouraged to identify and incorporate into their plans those 
geographical areas that are targeted for economic growth. The commenter 
further stated that these would include areas that are either receiving 
Federal, State, or local funds, or receiving funds from all of these 
sources, for the purpose of stimulating their economies, or areas that 
have been identified by local governmental or community based agencies 
for economic activity.
    Discussion: States are responsible for developing statewide School-
to-Work Opportunities systems. Each State plan must describe how the 
State will stimulate and support local School-to-Work Opportunities 
programs in the State, including in areas with high concentrations of 
poor and disadvantaged youth. As part of this effort, States will, of 
course, be encouraged to identify and incorporate in their plans, 
geographic areas that are targeted for economic growth. However, the 
Secretaries wish to reiterate that States and localities have the 
flexibility to determine those areas that should receive any priority 
in the establishment of statewide systems and for the receipt of funds 
allocated to local partnerships.
    Changes: None.

Priority--Collaboration To Implement the State School-to-Work 
Opportunities System

    Comment: One commenter requested that, in paragraph (b)(2) of the 
priority, the phrase ``including State agency officials responsible for 
special education, vocational rehabilitation, and other transition 
services'' be added following the reference to ``other appropriate 
officials.'' This commenter believed that all appropriate interagency 
experts must be included in a collaborative effort toward 
implementation of each State's School-to-Work Opportunities system.
    Discussion: The Secretaries agree that the implementation of each 
State's School-to-Work Opportunities system must be a collaborative 
effort involving numerous officials within the State. Systemic change 
and the provision of appropriate education, training, and employment 
opportunities for all students cannot be achieved otherwise. However, 
beyond specifying the involvement of the Governor, the State 
educational agency, the State agency officials responsible for job 
training and employment, economic development, and postsecondary 
education as the priority does the Secretaries have opted not to 
dictate to States which additional State officials must be included in 
this collaborative effort. The Secretaries do, however, encourage the 
collaboration of those officials named by the commenter and, in fact, 
list ``rehabilitation agencies and organizations'' among those entities 
which the State should actively involve in the implementation of 
statewide systems.
    Changes: None.

Priority--Active and Continued Involvement by Interested Parties

    Comments: In addition to the interested parties specifically listed 
in paragraph (b)(3) of the priority as those whose active and continued 
involvement must be demonstrated in order for an application to be 
given absolute priority, several commenters suggested that the 
Secretaries add specific references to the following additional 
interested parties: Language minority communities, Private Industry 
Councils, related services personnel (such as vocational rehabilitation 
counselors and job coaches) following the word ``teachers,'' and human 
services agencies. One commenter suggested that teachers be moved to 
the top of the existing list of interested parties in order to indicate 
that priority will be assigned to applications placing priority upon 
the cooperation of teachers. Two of the commenters were particularly 
interested in ensuring the active and continued involvement of those 
parties that are most critical to the preparation of disabled 
populations for work and that are essential to the success of disabled 
youth within the job setting.
    Discussion: The Secretaries agree that the active and continued 
involvement of each of the parties named by the commenters would be 
entirely appropriate under paragraph (b)(3) of the priority notice, and 
have revised paragraph (b)(3) accordingly. Specifically, with regard to 
Private Industry Councils established under the Job Training 
Partnership Act and with regard to vocational rehabilitation personnel, 
the Secretaries wish to point out that, in the definition of the term 
``partnership,'' these have been specifically named by the Secretaries 
as parties that may be included within partnerships. In addition to the 
parties suggested by the commenters, the House and Senate School-to-
Work Opportunities bills include vocational student organizations and 
State or regional cooperative education associations to the list of 
other interested parties. The Secretaries have added vocational student 
organizations and State and regional cooperative education associations 
to paragraph (b)(3) because the Secretaries consider these two entities 
to be appropriate additions to the list of parties that may be involved 
in the State School-to-Work Opportunities system, and to ease the 
transition from funding under this Notice to funding under anticipated 
School-to-Work Opportunities legislation. In adding the parties 
suggested by the commenters and the parties in the House and Senate 
bills, the Secretaries wish to emphasize that the list of other parties 
in paragraph (b)(3) is purely illustrative of the types of parties 
whose active and continued participation in a State's School-to-Work 
system would be appropriate. Thus, while the Secretaries will place an 
absolute priority upon applications that provide for the active and 
continued involvement of employers and other interested parties, the 
Secretaries have chosen to allow each State the flexibility to 
determine which parties in addition to employers would most effectively 
assist the State to implement its School-to-Work Opportunities system.
    Changes: Section (b)(3) of the final priority has been revised to 
add to the illustrative list of ``other interested parties'' the 
following entities: Related services personnel, human services 
agencies, language minority communities, Private Industry Councils 
established under the Job Training Partnership Act, vocational student 
organizations, and State or regional cooperative education 
associations.
    Comment: One commenter noted that the October 14, 1993 notice 
contained no mention of how comprehensive high schools would be 
involved and served under the School-to-Work Opportunities State 
Implementation Grants program, suggesting the need for clarification on 
the involvement of comprehensive high schools. The commenter was 
concerned that changes were needed in order to ensure a viable role in 
the program not merely for vocational high schools but also for 
comprehensive high schools and recommended that references to 
comprehensive high schools be added in paragraph (b)(3) of the priority 
as well as in other parts of the notice where secondary schools are 
discussed.
    Discussion: The Secretaries fully intend that comprehensive high 
schools be included in each statewide School-to-Work Opportunities 
system. In order to implement a comprehensive School-to-Work 
Opportunities system serving all students, States must ensure 
opportunities for the participation of all students, including students 
in comprehensive high schools. Under the School-to-Work Opportunities 
program and under this priority, it would be unacceptable for only 
vocational high schools, for example, to be included in a State's 
implementation plan. However, the Secretaries believe that specific 
reference to comprehensive high schools is unnecessary, since the term 
``secondary'' encompasses all schools at the secondary level.
    Changes: None.

Priority--Education and Training Funds Coordination

    Comment: Under paragraph (b)(4) of the priority notice, each State 
is required to describe how its comprehensive School-to-Work 
Opportunities system will coordinate the use of funds available from 
State and private sources with the use of funds available from other 
Federal programs. One commenter suggested that a clause be added to 
paragraph (b)(4) requiring the coordination of program activities 
funded with State and private sources with Federal program funds. The 
commenter also recommended that the JOBS program be specifically 
listed.
    Discussion: In response to the part of the comment suggesting that 
a specific reference be added to paragraph (b)(4) to ``program 
activities'' supported with State or private funds, the Secretaries 
have concluded that such a reference is unnecessary. The requirement in 
that paragraph is for coordination of the use of Federal education and 
training funds. Included within the requirement articulated in 
paragraph (b)(4), is the requirement for coordination between the 
program activities supported with the State and private funds and the 
program activities supported with funding received under related 
Federal statutes. The Secretaries agree that the JOBS program should be 
specifically listed. However, it is important to note that the list of 
Federal programs in paragraph (b)(4) is not an exhaustive list of 
related Federal programs with which the use of State and private funds 
should be coordinated.
    Changes: A specific reference to JOBS has been added to paragraph 
(b)(4) of the priority notice.

Priority--Assessing Skills and Knowledge and Participation in the Goals 
2000: Educate America Act

    Comment: Several commenters stated that in paragraph (b)(9), which 
requires States to describe their processes for assessing the skills 
and knowledge required in career majors and in awarding skills 
certificates that take into account the work of the proposed National 
Skill Standards Board and the criteria established under the proposed 
Goals 2000: Educate America Act, the priority ignores the fact that 
participation in Goals 2000 is voluntary. One commenter noted that 
requiring students to receive a skill certificate, as a common feature 
of the program, assumes that the Goals 2000: Educate America Act, which 
contains provisions for voluntary industry-based skill standards, will 
be enacted into law. This commenter felt that it was inconsistent to 
require a skill certificate based on enactment of a law which 
establishes only voluntary, industry-based, skill standards. 
Accordingly, the commenters suggested that language be added to this 
paragraph of the priority notice, indicating that the standards or 
criteria developed under Goals 2000 will only be required if the State 
is participating in Goals 2000.
    Discussion: An important goal of the School-to-Work Opportunities 
program is to facilitate the employment of young Americans in high-
skill, high-wage occupations. Enhancing the ability of job applicants 
to demonstrate that they possess high quality skills is one way to 
promote access to such employment. A skill certificate can provide that 
credential and thereby enhance job prospects. Therefore, the 
Secretaries believe that this is a crucial component and should be a 
required outcome. Participation in both the proposed Goals 2000 program 
and the School-to-Work Opportunities program is entirely voluntary. 
However, should a State elect to participate, the Secretaries expect 
that skill certificates will be awarded and that they will take into 
account the criteria proposed in Goals 2000 as well as the work of the 
National Skills Standards Board. These criteria are intended to promote 
the highest quality and most internationally competitive standards 
possible, in order to facilitate high-wage, high-skill employment.
    Changes: None.
    Comment: One commenter supported the linking of skill certificates 
to the National Skill Standards Board and observed that these standards 
should be the direct goal of each State's efforts, otherwise the skills 
standards would have little use. This commenter believed that the 
standards should also be linked to the academic standards of the 
National Council of Teachers of Math (NCTM) and the National Council of 
Teachers of Science (NCTS).
    Discussion: The Secretaries agree that input from the NCTM and NCTS 
would be helpful and expect that they will be a part of the process 
under which academic standards are set.
    Changes: None.

Priority--Opportunities for All Students

    Comments: Several commenters requested that the Secretaries expand 
upon the requirement in paragraph (b)(6) of the October 14, 1993 notice 
(redesignated as (b)(7) of this notice), under which States must 
describe how they will ensure opportunities for participation for all 
students. The commenters requested that this be done by requiring 
States to describe how opportunities will be provided, particularly to 
low-achieving, disabled, and limited-English proficient students. One 
commenter noted that paragraph (b)(8) of the October 14, 1993 notice 
should be redrafted in a manner similar to paragraph (b)(7) of the 
October 14, 1993 notice, under which States were required to describe 
the manner in which opportunities will be provided for young women to 
participate in School-to-Work Opportunities programs in a manner 
leading to meaningful employment opportunities.
    Discussion: The Secretaries intend the requirement in paragraph 
(b)(8), redesignated as (b)(9) of this notice, relating to low-
achieving students, students with disabilities, and dropouts, to 
provide the same threshold for serving those students, as the language 
in redesignated paragraph (b)(8) of the final priority, with regard to 
serving young women. In both paragraphs, the Secretaries intend to seek 
descriptions from States as to how they will ensure opportunities for 
students to participate in a meaningful and productive manner in the 
School-to-Work Opportunities program.
    Changes: Paragraph (b)(9) has been changed to require each State to 
describe how it will ensure opportunities for low achieving students, 
students with disabilities, and former students who have dropped out of 
school, to participate in School-to-Work Opportunities programs in a 
manner that leads to employment in high-performance, high-paying jobs.
    Comment: Three commenters requested, that in lieu of describing the 
manner in which they will ``ensure'' opportunities for students to 
participate in the School-to-Work Opportunities programs in paragraphs 
(b)(6) through (b)(8) of the October 14, 1993 notice, States be 
required to ``increase'' opportunities for students to participate in 
the School-to-Work Opportunities programs.
    Discussion: The Secretaries believe that requiring States to ensure 
opportunities for student participation will naturally result in 
increased opportunities for participation. Therefore, the Secretaries 
do not think that the suggested change is necessary.
    Changes: None.

Priority--Stakeholder Agreement

    Comment: While agreeing that all the items in the notice are 
critical, one commenter suggested that perhaps the most critical item 
would be one requiring an agreement among ``stakeholders'' setting out 
the results to be achieved by each State's program, how achievement of 
these results would be determined by stakeholders, and what agency 
would be entrusted with the review of program results. The commenter 
suggested that an independent or quasi-independent entity would be best 
suited for the role of evaluating program success.
    Discussion: The Secretaries agree that the ideas presented by the 
commenter, including that relating to agreements among stakeholders, 
are good ones. While the Secretaries think that stakeholder agreements 
may be very effective ways of ensuring meaningful collaboration, they 
are opposed to making them mandatory. Rather, each State is allowed the 
flexibility to determine the best way to ensure effective collaboration 
among the stakeholders and the specific methods and processes by which 
the progress of its program will be reviewed and assessed.
    Changes: None.

General Program Requirements--Common Features

    Comment: Two commenters noted that, to allow individuals with 
disabilities to fully participate in School-to-Work Opportunities 
programs, the wording on outcomes must be revised to add, after ``a 
high school diploma,'' the phrase, ``or alternative diploma or 
certificate, as appropriate.''
    Discussion: The Secretaries seek to establish systems that will 
result in the attainment of a high school diploma or its equivalent, 
and a skill certificate, for all students. States have the flexibility 
to provide support services to students who may require additional 
resources to obtain the outcomes sought to be achieved under the 
program. However, as has been discussed above, the Secretaries do not 
intend to discourage the participation of students with disabilities in 
State School-to-Work Opportunities programs. Indeed, the School-to-Work 
Opportunities initiative is intended to serve all students. 
Accordingly, the Secretaries include within the term ``equivalent,'' 
which has been added to the definition of ``career major,'' 
certificates which States may choose to provide to students with 
disabilities. These are considered to be equivalent to high school 
diplomas.
    Changes: Paragraph (b)(1) of the ``General Program Components'' 
section of the priority has been revised to indicate that the high 
school diploma requirement may be satisfied when a student is awarded 
the ``equivalent'' of a high school diploma, as determined under 
standards by the State.

Program Components--General

    Comment: One commenter considered the three program components 
contained in the October 14, 1993 notice to be inadequate and suggested 
that a section for support activities like counseling, child care, and 
transportation, be added. The commenter felt that without these support 
activities, programs would not attract and hold students who were drop-
outs, young parents, or disadvantaged, and whose past lack of success 
had been due to the unavailability of such services.
    Discussion: The program components required in the notice define 
the core elements of a School-to-Work Opportunities program. The 
Secretaries recognize that other support services may be necessary to 
help students fully participate in the program, particularly in the 
case of disadvantaged or disabled students, and in the case of 
dropouts. The Secretaries do not, however, wish to render such 
additional services mandatory in all cases. Moreover, under the notice, 
States are already required to ensure opportunities for ``low-achieving 
students, students with disabilities, and former students who have 
dropped out of school to participate in School-to-Work Opportunities 
programs.'' This will mean in some cases, providing support services. 
Also, it is important to note that funds under this competition may be 
used for support services. In addition, under the priority, States are 
required to describe how their School-to-Work Opportunities systems 
will coordinate the use of education and training funds from State and 
private sources with funds available from related Federal programs. 
(See paragraph (b)(4) of the priority.)
    Changes: None.

Program Components--Work-Based Learning Component

    Comment: One commenter recommended that the reference to 
``instruction in a variety of elements of an industry'' in the work-
based learning section of program components, be revised to read: 
``instruction in all aspects of an industry.'' The commenter further 
recommended that the revised terminology be added to the requirement 
for school-based learning.
    Discussion: The Secretaries agree with the commenter that the 
reference to instruction in a variety of elements of an industry should 
not be a reference that is limited to the work-based component of the 
program. Further, as previously discussed, there has been a change from 
use of the term ``Elements of the industry'' in the October 14, 1993 
notice, to use of the term ``All aspects of the industry.''
    Change: The reference to ``Broad instruction in a variety of 
elements of an industry'' has been deleted from the work-based learning 
component of the ``General Program Requirements'' section. Paragraph 
(a)(1) of the basic components section has been revised to provide that 
one of the bases of a School-to-Work Opportunities system is the 
integration of work-based learning and school-based learning ``that 
provides participating students, to the extent practicable, with broad 
instruction in all aspects of the industry the students are preparing 
to enter.''
    Comment: Several commenters felt that businesses may experience 
difficulty in providing students with paid work experience, 
particularly special needs students. One commenter stated that the 
proposed requirements for work-based learning ignore the basic reality 
that only a small minority of firms now provide significant training to 
their own line workers below the management level--let alone to 
``marginal'' high school youth. This commenter believed that the 
requirements for work-based learning should be expanded to include 
school-based work placements such as student-run enterprises and 
school-sponsored community service programs, provided they are of 
sufficient quality and intensity to otherwise meet the quality 
requirements of the initiative.
    Discussion: The Secretaries believe that paid work experience is an 
important component of work-based learning in school-to-work programs. 
Experts consulted in the development of this priority and in the 
development of the proposed School-to-Work Opportunities legislation 
strongly believe that jobs with pay increase employment experience for 
youth, as well as increasing the value and importance of the youth to 
the employer. Studies confirm these beliefs. Employers have continually 
pointed out that paying wages is not the primary consideration in their 
decision of whether or not to participate in school-to-work programs. 
Small and medium sized businesses have a special incentive since these 
have been found to be the most significant sources of employment for 
youth. At the same time, however, the Secretaries agree that it is 
important for partnerships to have as much flexibility as possible in 
developing school-to-work programs, including having input on how the 
paid work experience is constructed. For that reason, the priority 
provides substantial flexibility. The priority does not require a 
minimum amount of paid work experience nor does it specify at which 
point in a program the paid work experience must occur. School-based 
enterprises can provide the contexts in which the paid work experience 
requirement could be met. In addition, other non-paid work experience, 
such as job shadowing or on-the-job training for academic credit, are 
not precluded by this priority, as complements to the paid work 
experience component.
    Changes: None.
    Comment: One commenter believed that the October 14, 1993 notice 
provides no real incentive for employers, particularly small 
businesses, to spend their limited funds on hiring students. This 
commenter would have the Secretaries include at least a sentence 
describing the potential use of Targeted Jobs Tax Credits, to remind 
grantees that they can make use of an existing incentive in their 
implementation of their School-to-Work programs.
    Discussion: The Secretaries agree with the commenter that there are 
many existing vehicles, such as Targeted Jobs Tax Credits, of which 
employers can avail themselves in the context of their involvement as 
partners in their States' School-to-Work Opportunities programs. In the 
course of providing technical assistance to the various States 
receiving funding under this competition, the Secretaries plan to 
inform States of any additional Federal resources, programs, or 
initiatives that may assist States, partnerships, and members of 
partnerships, in meeting the goals of the initiative and in 
implementing their State School-to-Work Opportunities plans. 
Importantly, there may be instances where it will be possible to use 
Job Training Partnership Act funds to pay for work-based activities for 
economically disadvantaged students. Funds awarded under this 
competition may be used by employers to cover costs associated with the 
work-based learning component of the program--for example, the training 
of mentors. In addition, States may develop their own package of State 
incentives to make participation more feasible or attractive for 
employers.
    Finally, the Secretaries strongly believe that the connecting 
activities authority will provide significant support to participating 
employers and to education institutions.
    Changes: None.
    Comment: One commenter believed that the notice should permit 
students to receive some of their school-based instruction in the 
workplace, regardless of whether the learning experience is paid or 
unpaid.
    Discussion: Under the School-to-Work Opportunities program, 
students receive academic instruction from teachers at the school 
setting, while receiving hands-on, work experience, including paid work 
experience, from workplace mentors at the job site. The School-to-Work 
Opportunities initiative is intended to break down barriers between 
school and work and to provide States and local partnerships with 
flexibility to design programs that contain the basic program 
components within the local context. Assuming that requirements of the 
three core components are otherwise satisfied, some degree of overlap 
between the work-based and the school-based learning components, would 
not necessarily be impermissible, and may, at times, be appropriate.
    Changes: None.
    Comment: One commenter noted that, to serve students with 
disabilities, including those with severe disabilities, the Secretaries 
should add, after ``paid work experience,'' the phrase, ``including 
supported employment.''
    Discussion: See discussion regarding paid work experience and the 
flexibility surrounding it as well as previous discussions regarding 
the requirement to ensure opportunities for all students, including 
disabled students. Also, as previously discussed, funds awarded under 
this competition may be used to help employers provide necessary 
support to students, including disabled students.
    Changes: None.
    Comment: One commenter felt that States should be required to show 
a broad and industry-wide commitment from employers to ensure that 
students get the necessary industry-wide exposure.
    Discussion: The Secretaries agree with the commenter that a 
demonstration of industry-wide commitment to the School-to-Work 
Opportunities program by any participating State is important toward 
ensuring that employers are seriously committed to their State's 
program and that all students are provided with adequate industry-wide 
exposure. Conversely, employer involvement is important in ensuring 
that School-to-Work Opportunity programs are responsive to business 
needs. However, under the ``Comprehensive Statewide System'' selection 
criterion and the ``Collaboration and Involvement of Key Partners'' 
selection criterion, the notice already addresses the commenter's 
concerns. Under these criteria, States must demonstrate and describe 
the commitment of employers and of State agency officials responsible 
for job training and employment.
    Changes: None.
    Comment: One commenter noted that current co-op initiatives in 
community colleges should be recognized and promoted in the notice. The 
commenter believes that these initiatives have the established 
infrastructure to implement school-to-work initiatives, including 
networks of co-op administrators, job developers, faculty coordinators, 
career counselors, and employer site supervisors. The commenter stated 
that community colleges are positioned to link co-op programs between 
secondary and postsecondary institutions and to improve their quality.
    Discussion: The Secretaries agree with the commenter that community 
colleges and programs sponsored by community colleges can make a 
significant contribution to statewide school-to-work initiatives and 
systems. In applying under this competition, States are to ``describe 
the procedure for obtaining the active and continued involvement in the 
statewide School-to-Work Opportunities system of employers and other 
interested parties such as * * * postsecondary educational institutions 
* * *.'' As the commenter notes, it is very possible that a co-op 
program could be included as part of a School-to-Work Opportunity 
system, so long as it meets the basic program requirements. The 
Secretaries would expect States to discuss in their plans how they will 
build on, modify, and enrich the efforts of community colleges to 
develop comprehensive School-to-Work Opportunities systems that meet 
the requirements of this priority.
    Changes: None.

General Program Requirements--School-based Learning Component

    Comment: One commenter stated that School-to-Work Opportunities 
systems will never achieve their intended goal of creating high-quality 
opportunities for all American youth unless programs contain: (1) 
``Enabling tools'' to provide students and parents with the 
information, assistance, capacity, and (2) safeguards necessary to 
obtain the opportunities promised by the School-to-Work Opportunities 
program. The commenter believed that it was necessary to provide 
parents with: (a) An unambiguous statement targeted to all youth of the 
opportunities provided by the program; (b) the information, assistance, 
and authority for targeted youth and their parents to obtain access to 
program opportunities, participate in shaping programs, and remedy the 
problems that will inevitably occur; (c) systems for ensuring that 
information about these program opportunities and involvement in 
shaping the programs extends beyond the school district central offices 
to the teachers; and (d) a statement of responsibilities for both 
technical assistance and overseeing local implementation.
    Discussion: The Secretaries agree that providing program 
information to both parents and students, is essential to a student's 
successful participation in, and completion of, a School-to-Work 
Opportunities program. For that reason, they have added under 
``examples of statewide activities,'' the clause ``working with 
localities to develop strategies to recruit and retain all students in 
programs, including those from a broad range of backgrounds and 
circumstances,'' and, as an example of activities for local 
partnerships, they have added the clause ``conducting outreach to all 
students in a manner that most appropriately meets the needs of their 
communities.'' Also, under paragraph (b)(3) of the priority, States are 
required to describe their procedure for obtaining the continued 
involvement of ``employers and other interested parties, such as * * * 
students, parents * * *.'' Moreover, under the Student Participation 
selection criterion, the Secretaries will evaluate whether each State 
has proposed realistic strategies and programs to ensure that all 
students have the opportunity to participate in the State's School-to-
Work Opportunities program. The Secretaries expect that a part of each 
State's strategy for ensuring participation would be providing 
information to all students about opportunities that are available to 
them within the program. However, beyond these provisions, the 
Secretaries are opposed to imposing further requirements upon States 
governing the formulation and nature of the program information 
disseminated.
    Changes: The section on ``Examples of Statewide Activities'' has 
been revised to include ``working with localities to develop strategies 
to recruit and retain all students in programs including those from a 
broad range of backgrounds and circumstances.'' As an example of 
``Activities for Local Partnerships'' the following has been added: 
``Conducting outreach to all students in a manner that most 
appropriately meets their needs and the needs of their communities.''
    Comment: One commenter observed that the academic outcomes expected 
from school-based learning should qualify students to enter and succeed 
in four-year postsecondary institutions upon graduation from high 
school. This commenter saw a significant possibility that students who 
enter a School-to-Work Opportunities program will face barriers to the 
full range of postsecondary institutions, feeding parents' and 
educators' tracking concerns. The commenter also believed that the 
imperative for students to meet entrance requirements for four-year 
institutions is made more critical by the early age at which youth will 
be encouraged to select a ``career major.''
    Discussion: The School-to-Work Opportunities initiative is not 
limited to non-college-bound students. Rather, it is intended for all 
students. The definition of the term ``All students'' refers to 
students from a broad range of backgrounds and circumstances 
``including * * * academically talented students.'' The notice states 
that career majors would typically include two years of secondary 
schools and one or two years of postsecondary education. As a result of 
their participation in a School-to-Work Opportunities program, students 
who are completing their first or second years at the postsecondary 
level would be encouraged to consider different options in employment 
and education, including enrollment in a four-year degree granting 
college or university. In addition, since students in School-to-Work 
Opportunities programs will be held to high academic standards, 
including, where applicable, those developed under Goals 2000, the 
Secretaries expect that these high standards will ensure that students 
who have participated in their State's School-to-Work Opportunities 
program are academically prepared for enrollment in four-year 
postsecondary institutions. However, in response to this comment as 
well as other related comments, the definition of ``career major'' has 
been revised to include admission to a degree-granting college or 
university as a possible outcome.
    Changes: The definition of ``Career major'' has been revised to 
include admission to a degree-granting college or university as a 
possible outcome for participating students.
    Comments: Two commenters stated that the proposed school-based 
learning component is inadequate with regard to the degree of 
participation that it requires from businesses and industries in such 
areas as planning, curriculum and program development, instruction, 
evaluation, and job placement. The commenters felt that the notice 
fails to take sufficient advantage of many effective ways in which 
business can be a partner with education throughout the entire 
instructional process prior to actual paid job placement.
    Discussion: The Secretaries strongly concur with the commenters 
that the active and continued involvement of business and industry is 
essential to the effective integration of school-based and work-based 
learning. Under this competition, business and industry involvement is 
a requirement, as provided for in paragraph (b)(3) of the priority 
contained in this notice. Plans will be reviewed for evidence of such 
involvement, as provided for in paragraph (b)(2) of the selection 
criteria, ``Collaboration and Involvement of Key Partners--Involvement 
by key parties.'' Moreover, the School-to-Work Opportunities program 
does not limit the involvement of business and industry nor limit their 
roles in the collaborative partnerships. Indeed, business will 
necessarily play a key role in the design as well as the implementation 
of each State's School-to-Work Opportunities program.
    Changes: None.
    Comment: One commenter believed that, while still in school, 
students should be linked with the workplace for mentoring, job-
shadowing, and other context-based experiences that can contribute to 
increased program completion and employment. Another commenter believed 
that businesses should provide significant input to the design of 
curriculum, provide mentors, pay students, develop skills standards, 
and employ youth. This commenter advocated the involvement of employers 
who currently participate in work and learning programs, rather than 
merely involving industry leaders.
    Discussion: The Secretaries strongly concur with both of these 
commenters but believe that the notice currently addresses their 
concerns.
    Changes: None. 
    Comment: One commenter was of the opinion that there is virtually 
no capacity in schools or anywhere else to counsel students on career 
majors and suggested that this area of the initiative be considered 
further. Another commenter noted that the school-based learning 
component does not specify when career counseling should begin. A third 
commenter suggested that, since the first bullet under ``school-based 
learning'' suggests that career majors may be ``reconsidered,'' a 
second bullet should be added immediately under it, to read: ``School-
based learning that includes the integration of occupational 
information and career development assistance into academic instruction 
and the availability to students of direct access to that occupational 
information and those career development assistance tools that relate 
occupational choice to educational attainment.'' The commenter believed 
that, without this additional requirement, the choices made by students 
may not be realistic or appropriate.
    Discussion: The Secretaries agree that, in many cases, students do 
not receive the guidance and counseling needed to make important 
decisions related to education and training leading to meaningful 
employment. It is for this reason that career exploration and 
counseling is required as an important activity in the school-based 
learning component of the notice. States seeking to receive a grant 
under this competition must demonstrate that the school-based learning 
component of their School-to-Work Opportunities systems will include 
career exploration and counseling. In addition, however, in response to 
the commenter's concerns, the Secretaries have revised the School-based 
Learning component to require, among other stated elements, ``career 
awareness and exploration and counseling (beginning at the earliest 
possible age)'' in order to help those students who may be interested, 
to identify and select or reconsider, their interests, goals, and 
career majors, ``including those options that may not be traditional 
for their gender, race or ethnicity.'' By this change, the Secretaries 
wish to emphasize the importance of career awareness and exploration at 
an early age. The determination of the actual age or grade level at 
which this activity should begin, has been left to the States.
    Changes: The School-based Learning component has been revised to 
require, among other stated elements, ``career awareness and 
exploration and counseling (beginning at the earliest possible age)'' 
in order to help those students who may be interested, to identify and 
select or reconsider, their interests, goals, and career majors, 
``including those options that may not be traditional for their gender, 
race, or ethnicity.''

General Program Requirements--Connecting Activities

    Comment: One commenter believed that the description of information 
collection and analysis in the connecting activities component of the 
``General Program Requirements'' of the priority is too general to 
provide useful information. The commenter believed that the information 
should include annual participation and post-program outcomes, and that 
the data should be ``disaggregated'' by gender, race, ethnicity, socio-
economic background, limited-English proficiency, and disability, so 
that any lack of participation or achievement by one group would not be 
masked by the success of the program for the general population.
    Discussion: The Secretaries agree with the commenters that 
disaggregated data is likely to be important for determinations of the 
success of the program for all groups. They would expect that the 
information collected and analysis provided under the connecting 
activities component to describe student participation in the program. 
This may include information on gender, race, ethnicity, socio-economic 
background, limited-English proficiency, and disability.
    Changes: A change has been made to the ``General Program 
Requirements Connecting Activities'' section of notice so that it is 
specified that among the information that may be collected is 
information on gender, race, ethnicity, socio-economic background, 
limited-English proficiency, and disability.
    Comment: One commenter requested that the Secretaries add the 
following additional requirement to the list of connecting activities 
in the priority: ``Providing job coaching services to youth with 
disabilities within a supported employment model.'' The commenter 
believed that job coaches could help students acquire job skills and 
could help employers achieve the workplace accommodations that may be 
necessary to job success.
    Discussion: As is provided for in the school-based and work-based 
learning components respectively, career exploration and counseling, as 
well as workplace mentoring, must be provided to all students. In 
addition, the notice requires States to describe in their applications 
how they will ensure opportunities for all students, including students 
with disabilities, to participate in School-to-Work Opportunities 
programs. While the Secretaries believe that funds awarded under this 
competition may be expended to cover the costs of what the commenter 
has referred to as job coaching for disabled students within a 
supported employment model, States may also seek to utilize funds 
available from other sources to meet what may be the special needs of 
disabled students participating in their School-to-Work Opportunities 
programs. Indeed, under paragraph (b)(4) of the priority, States are 
specifically required to describe how their School-to-Work 
Opportunities systems will coordinate the use of education and training 
funds from State and private sources with related Federal program 
funds.
    Changes: None.

Examples of Statewide Activities

    Comment: One commenter requested the inclusion of ``related 
services personnel'' among those individuals for whom training could be 
provided by a grantee receiving funds under this competition. The 
commenter felt that related services personnel would be critical to the 
success of students with disabilities in School-to-Work Opportunities 
programs and that these individuals should be trained along with the 
teachers and other professionals named in paragraph (c) under 
``Examples of Statewide Activities.''
    Discussion: Under the section of the notice entitled ``Examples of 
Statewide Activities'' there is a list which is meant only to be 
illustrative and to provide examples of some of the grantee 
expenditures that would be allowable under this program. The 
Secretaries agree that the costs of training related services personnel 
is sufficiently important to be added to the list as an allowable 
expenditure under this program.
    Changes: Reference to ``related services personnel'' has been added 
to the list of those individuals for whom training could be provided by 
a grantee under this program.
    Comment: One commenter recommended that examples should be added to 
the list of statewide activities to focus on the needs of disadvantaged 
youth and poor communities. The commenter proposed adding, as an 
example of allowable statewide activities, stimulating the development 
of partnerships in poor communities, and providing training and 
dissemination of curricula to local partnerships to more effectively 
respond to the needs of disadvantaged youth.
    Discussion: The Secretaries agree with the commenter that the 
examples of statewide activities should include activities aimed at 
addressing the particular needs of disadvantaged youth and poor 
communities. Accordingly, paragraph (b) of the examples has been 
revised to include stimulating the development of partnerships in poor 
communities. The Secretaries note that the statewide activities as 
proposed include the training and curricula dissemination activities 
cited by the commenter, for teachers, employers, workplace mentors, and 
others, at the local level. However, the Secretaries believe that an 
additional activity should be added, to clarify that States may assist 
localities in formulating strategies to recruit and retain all students 
including the poor and disadvantaged. These strategies may include the 
training and curricula dissemination activities described in paragraphs 
(c) and (e) of the examples.
    Changes: Paragraph (b) under ``Examples of Statewide Activities'' 
has been revised to include the clause: ``Stimulating the development 
of partnerships in poor communities'' as an outreach activity to 
promote and support collaboration in School-to-Work Opportunities 
programs. In addition, a new paragraph (h) has been added to provide 
that States may work ``with localities to develop strategies to recruit 
and retain all students in School-To-Work Opportunities programs, 
including those from a broad range of backgrounds and circumstances.''

Allocation of Funds to Local Partnerships

    Comment: One commenter felt that the Secretaries should require 
local partnerships to describe how they will train counselors and other 
personnel to provide minority, female, disabled, and limited-English 
proficient youth with access to high-skill, high-wage, non-traditional 
careers. The commenter believed that such a requirement should be 
included in this section on ``Allocation of Funds to Local 
Partnerships'' and that it should be given as an example in the 
succeeding section, ``Examples of Activities for Local Partnerships.''
    Discussion: The Secretaries agree that training is an important 
activity, and have included ``training for teachers, employers, 
workplace mentors, counselors, and others,'' as examples of State 
activities and ``providing training to work-based and school-based 
staff on new curricula, student assessments, student guidance, and 
feedback to the school regarding student performance,'' as examples of 
local partnership activities. Also, one of the requirements under 
school-based learning is ``career awareness and career exploration and 
counseling in order to help students who may be interested to identify 
and select or reconsider their interests, goals, and career majors.'' 
The Secretaries do not wish to mandate to local partnerships who should 
be trained or how the training should be accomplished. Rather, the 
Secretaries think it is preferable for local partnerships to make those 
determinations in ways that best serve the programs which they are 
implementing and the students participating in those programs.
    Changes: None.

Examples of Activities for Local Partnerships

    Comment: Two commenters had suggestions regarding the ``Examples of 
Activities for Local Partnerships'' provided in the notice. One 
commenter believed that paragraph (f) (redesignated as paragraph (g)) 
should be changed to specifically allow students with disabilities to 
participate in graduation assistance programs to help them graduate 
from high school, continue their education or training, and to find 
jobs as well as advance in them. The second commenter requested the 
Secretaries to add the word, ``all,'' before ``at risk and low-
achieving students'' in paragraph (f) (redesignated as paragraph (g)). 
The commenter felt that this change was necessary to ensure that all 
categories of students listed in the definition of ``All students'' 
would be served. The commenter also suggested changing the last phrase 
in paragraph (f) of the October 14, 1993 notice, to read, ``* * * and 
finding, maintaining or advancing in jobs,'' to emphasize that 
maintaining a job is equally as important as finding one.
    Discussion: The Secretaries agree with commenters that graduation 
assistance programs should be geared to serving all students, as 
defined in the notice, and that the activity described in redesignated 
paragraph (g) should clearly refer to disabled students as well as to 
at-risk and low-achieving students. The Secretaries also believe that 
``maintaining a job'' is consistent with the desired outcomes of the 
School-to-Work Opportunities initiative and of this competition, and 
have added the word, ``maintaining'' to redesignated paragraph (g) of 
the ``Examples of Activities for Local Partnerships.'' The commenter on 
the availability of occupational information and career development 
assistance has suggested two, among what may be many, additional 
worthwhile activities that might be carried out under a local 
partnership. The Secretaries, because this section is purely 
illustrative and in the interest of brevity, have elected not to 
include them in the final priority. Although the Secretaries find 
commendable, the suggestion to require that all at-risk and low-
achieving students be served in a graduation assistance program, the 
Secretaries fully understand the difference between ``equal access to 
opportunity'' and a ``guarantee,'' and, because of the limited 
resources available, have elected to have local partnerships provide 
``opportunity for all students'' in preference to a guarantee.
    Changes: The notice has been modified by adding the word, 
``disabled'' to redesignated paragraph (g) in the section on ``Examples 
of Activities for Local Partnerships,'' so that it now reads: ``* * * a 
graduation assistance program to assist at-risk, disabled, and low-
achieving students, in graduating from high school. * * *.'' In 
addition, the Secretaries have modified this same paragraph by adding 
the word ``maintaining'' to the end of the paragraph. Accordingly, the 
notice now provides, specifically, that funds awarded by States to 
local partnerships under this competition may be utilized for the 
purpose of assisting at-risk, disabled, and low-achieving students in 
graduating from high school, enrolling in postsecondary education or 
training, and finding, maintaining, or advancing in jobs.
    Comment: One commenter, expressing concern with what he referred to 
as decisionmakers' access to occupational information, suggested adding 
two activities to the list of activities for local partnerships. The 
commenter suggested revising paragraph (h) to specifically authorize 
the creation of after school, School-to-Work career centers, where 
students and parents could seek occupational and career information, 
carry out career exploration, seek guidance regarding career choices or 
the design of an educational program, or evaluate the educational 
preparation that students have received to date. The commenter also 
suggested adding a paragraph to authorize the publication of career 
information for use by parents and students, in cooperation with the 
State Occupational Information Coordinating Committee.
    Discussion: The issue raised by the commenter is discussed earlier 
in the context of the School-to-Work Opportunities program's school-
based learning component. In this context also, in suggesting that 
funds awarded under this competition be utilized for preparing and 
making available important program information for parents and students 
in after school centers or in publication, the commenter has suggested 
an activity that the Secretaries would consider to be an allowable 
activity for local partnerships.
    Changes: None.

Examples of Activities for Local Partnerships--Youth

    Comment: One commenter felt that the notice's references to youth 
for example, in paragraph (h) of Examples of Activities for Local 
Partnerships in the context of providing opportunities for dropout 
students were unclear. The commenter suggested defining the term 
``youth'' so as to include, at a minimum, young persons up to, and 
including, age 25, to allow for the inclusion of young men and women 
who have dropped out, become parents, and face multiple obstacles to 
achieving a self-sufficient wage. Another commenter believed that 
defining the term ``youth'' to include students in the elementary 
grades would enhance the opportunities of children to develop early 
career awareness, thereby increasing School-to-Work Opportunities 
program participation rates in the high schools.
    Discussion: Since the focus of the School-to-Work initiative and of 
this notice is on system building and institutional change, there are 
no detailed provisions for individual eligibility. The Secretaries 
believe that States should have the flexibility to determine the age 
range of the student population for their School-to-Work Opportunities 
programs. However, States are expected to develop systems that 
coordinate other education and training programs funded from sources 
that do set parameters for the youth to be served. For example, the Job 
Training Partnership Act limits the age of the youth to be served to 16 
through 21 years of age. In addition, the required school-based 
learning component must include career awareness and career exploration 
and counseling. These activities may be carried out in the elementary 
and middle school years to better prepare students for School-to-Work 
Opportunities programs, as States and localities retain the flexibility 
to begin career awareness and counseling programs at as early a grade 
level as appears to be appropriate and useful.
    Changes: None.
    Comment: One commenter felt that a student's eligibility to 
participate in a School-to-Work Opportunities program should not be 
determined by student population based on age, such as age 16 through 
21, but rather should be geared to grade level. The commenter believed 
that a student's eligibility to participate in School-to-Work 
Opportunities program should begin in ninth grade, since, in this way, 
all students would have an equal opportunity to qualify for the 
program.
    Discussion: As is discussed above, the Secretaries believe that 
States should retain the flexibility to design School-to-Work 
Opportunities systems, within the parameters of the program as 
contained in this notice, that best meet the needs of their students.
    Changes: None.

Safeguards

    Comment: One commenter requested that the Secretaries establish 
additional safeguards, beyond those provided for in the notice, so as 
to ensure student access, services, information, and assistance to 
students and parents. Another commenter suggested adding a new 
safeguard to provide that nothing in this notice should be construed as 
modifying or affecting the Fair Labor Standards Act.
    Discussion: Regarding the applicability of the Fair Labor Standards 
Act, the Secretaries note that, as a matter of law, this notice does 
not and cannot in any way modify or affect either the Fair Labor 
Standards Act or its applicability. However, the Secretaries agree with 
the commenter's suggestion that a reference to applicable fair labor 
standards would be helpful in the context of the ``Safeguards'' section 
of the notice. Regarding the commenter's suggestion that additional 
safeguards be added to the list, the Secretaries do not believe that 
this is necessary, since relevant Federal and State law will continue 
to apply to this program, regardless of whether these are specifically 
mentioned or listed in the notice.
    Changes: The notice has been modified to include the word ``labor'' 
in paragraph (d) of the ``Safeguards'' section of the notice. Paragraph 
(d) now reads: ``Students shall be provided with adequate and safe 
equipment and a safe and healthful workplace in conformity with all 
health, safety, and labor standards of Federal, State, and local law.''

Selection Criteria--Comprehensive Statewide System

    Comment: In making choices among standards and assessments for 
occupational skills, one commenter suggested that States be required to 
consider whether the standards and assessments chosen reflect the needs 
of high-performance workplaces, whether they are benchmarked to the 
highest international standards, and whether they reflect requirements 
of clusters of occupations requiring similar skills, rather than 
individual jobs or occupations. The commenter suggested that among the 
needs of high performance work organizations are the acquisition of 
skills required to be an effective member of a work group, the capacity 
to learn new skills quickly, broad analytical and systems thinking 
skills, and specific skill sets that facilitate high mobility among a 
wide variety of related jobs and occupations within an industry and 
among different industries.
    Discussion: The Secretaries agree that State skill standards and 
methods of skill assessment must be benchmarked to high quality 
standards in order to ensure, to the extent possible, that students 
receiving portable skill certificates under the School-to-Work 
Opportunities program will have the opportunity to enter high-skill, 
high-wage, employment. Therefore, the clause ``benchmarked to high 
quality standards'' is added to the definition of the term ``Skill 
certificate.'' Similarly, a question has been added to the 
``Comprehensive Statewide Systems'' selection criterion requiring 
States to indicate in their applications whether their processes for 
assessing skills reflect the needs of high performance workplaces as 
well as meeting the requirements of broad clusters of related 
occupations and industries, rather than those of individual jobs or 
occupations. The Secretaries generally agree with the commenter that, 
in making their choices among standards and assessments for 
occupational skills, States should choose standards and assessments 
that build upon available standards and assessments; incorporate those 
skills that are necessary for employees to participate as active 
members of a work group and serve as team leaders; utilize high 
standards in an industry, occupation or profession; include measures of 
broad analytical and thinking skills; and reflect the requirements of 
clusters of occupations, requiring similar skills, rather than 
narrowly-defined individual jobs or occupations.
    Changes: In response to the commenter, the definition of the term 
``Skill certificate'' has been revised to require that skills be 
benchmarked to high quality standards. In addition, the following 
question has been added to the ``Comprehensive Statewide System'' 
criterion: ``Does the State's process for assessing skills reflect the 
needs of high performance workplaces as well as meet the requirements 
of broad clusters of related occupations and industries, rather than 
those of individual jobs or occupations?''
    Comment: One commenter suggested that the selection criterion 
``Comprehensive Statewide System'' include a question asking applicants 
to describe how their School-to-Work Opportunities system is a part of 
school-wide restructuring that provides every student in each school 
with experimental learning programs--hands-on learning, students' 
demonstration of skills through projects, mentoring and coaching 
relationships, and increased student self-esteem and motivation that 
are linked with academic education.
    Discussion: School-to-Work Opportunities systems under the priority 
established in this notice must integrate work-based learning and 
school-based learning. School-to-Work Opportunities programs must 
incorporate a planned program of job training and experiences, paid 
work experience, workplace mentoring, and a program of study designed 
to meet the same challenging academic standards developed for all 
students. The criterion ``Comprehensive Statewide System'' is intended 
to encourage applicants to describe how their proposed School-to-Work 
Opportunities systems will produce systemic statewide change that will 
have a substantial beneficial impact on the preparation of youth for 
either a first job or further training or education.
    This criterion also encourages States to describe State and local 
performance standards that lead to statewide systemic reform of 
secondary education. The ``Local Programs'' criterion is intended to 
elicit a detailed description of the School-to-Work Opportunities 
system to be implemented at the local level. The Secretaries expect 
that, combined, these criteria will result in applicants submitting 
descriptions of State plans that provide for fundamental statewide 
restructuring of existing education and training programs.
    Changes: None.
    Comment: One commenter who believed that community-based 
organizations and the human services sectors are currently under-
utilized, suggested that a question be added under the selection 
criterion ``Comprehensive Statewide System'' to read: ``Does the plan 
describe methods to ensure high school completion by participants such 
as graduation assistance programs targeting low-achieving and at-risk 
youth or offering human services in coordination with education and job 
training?'' One commenter was concerned that occupational and career 
information and career guidance and counseling be provided and 
suggested adding a question to read: ``Has the State incorporated into 
the Statewide plan provisions for the presentation of occupational and 
career information and career development assistance to all students in 
all parts of the State?''
    Discussion: The Secretaries agree with the commenter that in 
response to this notice applicants should describe the methods that 
they have selected to ensure high school completion. The criterion 
``Student Participation'', therefore, focuses on providing ``all 
students'', including low-achieving students, the opportunity to 
participate in School-to-Work Opportunities programs. The ``Local 
Programs'' criterion emphasizes that plans must include programs that 
result in the award of high school diplomas, as is otherwise required 
in the notice. With respect to the commenter's suggestion that 
statewide plans provide for the presentation of occupational and career 
information and career development assistance, one of the ``General 
Program Requirements'' already contained in the priority, is that the 
school-based learning component of any School-to-Work program include 
career exploration and counseling.
    Changes: None.

Selection Criteria--Collaboration and Involvement of Key Partners

    Comment: One commenter suggested adding State officials responsible 
for special education, vocational rehabilitation, and other transition 
services, to the list of State level officials with whom applicants are 
encouraged to collaborate in implementing statewide School-to-Work 
Opportunities systems. Other commenters suggested adding a variety of 
entities to the list of key parties to be involved in the 
implementation of States' School-to-Work Opportunities systems. 
Specifically, commenters suggested adding vocational and comprehensive 
high schools, local vocational education agencies, private industry 
councils established under the Job Training Partnership Act (JTPA), 
related services personnel, State Occupational Information Coordinating 
Committees and other occupational information providers, human services 
agencies, JTPA operators and educational programs serving farmworkers. 
One commenter was of the opinion that the involvement of other parties 
cannot serve as a substitute for the involvement of students, parents, 
teachers, and area residents in State and local decision-making. The 
commenter also felt that the statewide system should include as many as 
possible of the interested parties listed under the criterion 
``Involvement by Key Parties.''
    Discussion: The lists of entities under paragraphs (b) (1) and (2) 
of the selection criterion ``Collaboration and Involvement of Key 
Partners'' are not intended to be exhaustive, but, rather, are intended 
to provide examples of entities that should be involved in developing 
and implementing a successful School-to-Work Opportunities system. It 
is likely that the other entities suggested by the commenters also 
would contribute to the success of State and local School-to-Work 
Opportunities activities and it would be appropriate for State and 
local agencies to seek their involvement. In accordance with these 
criteria, as well as with paragraphs (b)(2) and (b)(3) of the priority, 
the Secretaries strongly encourage the involvement of all groups and 
entities that can perform useful and productive functions in the 
implementation of State School-to-Work Opportunities programs.
    Changes: None.

Selection Criteria--Student Participation

    Comment: One commenter felt that under the ``Student 
Participation'' selection criterion insufficient attention is accorded 
to the adequacy of plans to reach and serve out-of-school youth 
effectively and suggested adding a specific question to address this 
perceived deficiency. Another commenter said that the description of 
``all students'' in the selection criteria is inconsistent with the 
definition of the term in the notice's ``Definitions'' section, which 
includes students with limited-English proficiency. The commenter would 
have this population added to the selection criterion.
    Discussion: The priority established in this notice requires State 
plans to include realistic strategies and programs to ensure that all 
students have the opportunity to participate in School-to-Work 
Opportunities systems. With regard to the comment on service to out-of-
school youth, the Secretaries note that the definition of the term 
``All students'' has been modified to include students who have dropped 
out of school. The Secretaries recognize that the definition of ``All 
students'' includes individuals with limited-English proficiency and 
agree that, for consistency, the reference to students with limited-
English proficiency also should be included in this criterion.
    Changes: The ``Student Participation'' criterion has been modified 
to include specific reference to students with limited-English 
proficiency.
    Comment: One commenter was concerned that the children of migrant 
and seasonal farmworkers are often overlooked by States and suggested 
that the Secretaries add ``migrant and seasonal farmworker children'' 
among those explicitly intended to be served under the program. The 
commenter also suggested that States be encouraged to provide early 
intervention for youth, particularly youth at risk of dropping out of 
school at an early age.
    Discussion: As written, the ``Student Participation'' criterion 
calls for realistic strategies and programs to included all students. 
In States with migrant workers and seasonal farmworkers, this would 
include the children of those individuals. The Secretaries expect those 
students to be provided with the opportunity to participate in School-
to-Work Opportunities programs. Additionally, the Secretaries strongly 
encourage States to provide early intervention for youth, particularly 
youth at risk of dropping out of school at an early age.
    Change: None.

Selection Criteria--Local Programs

    Comment: One commenter suggested that the ``Local programs'' 
selection criterion be modified to permit supported employment as a 
part of work-based learning. The commenter was also concerned about the 
participation of special education students and suggested that the 
phrase ``or alternative certificate'' be added after ``award of a high 
school diploma.'' The commenter also felt that the phrase ``including 
those funded under JTPA, IDEA, Carl D. Perkins Vocational and Applied 
Technology Education Act (Perkins Act), the Rehabilitation Act, and 
JOBS'' should be added following the question ``Have promising existing 
programs been considered for adaptation?''
    Discussion: With regard to the suggestion that the ``Local 
programs'' selection criterion be modified to permit supported 
employment as a part of work-based learning, such a change would make 
the selection criterion inconsistent with the priority, which includes 
a safeguard prohibiting the use of funds awarded under this competition 
for the payment of wages to students. The Secretaries encourage 
grantees to use other Federal, State, local, public, and private 
resources to provide supported employment, work study, and cooperative 
education where these approaches facilitate work-based learning. With 
regard to the comment suggesting that alternative certificates be 
accepted in lieu of high school diplomas for disabled students, the 
clause ``or its equivalent'' is added to this part of the notice to 
provide for alternative certificates for disabled students. Finally, 
while the Secretaries agree with the commenter that programs under the 
JTPA, IDEA, Perkins Act, Rehabilitation Act, and JOBS have produced 
practices that should be considered for adaptation, other Federal, 
State, and local programs have also developed promising programs that 
States and locals may wish to consider. The Secretaries encourage 
States and localities to adapt all promising programs to their School-
to-Work Opportunities systems in a manner that best suits the systems 
they plan to implement.
    Changes: The clause ``or its equivalent'' has been added to the 
definition of the term ``Career major,'' to the ``General Program 
Requirements'' section of this notice, and to the ``Local Programs'' 
criterion, providing for alternative certificates for disabled 
students.

Selection Criteria--Management Plan

    Comment: One commenter felt that greater emphasis should be given 
to States that present new or alternative methods of assessment for 
their activities. This commenter also believed that priority should be 
given to applicants that are able to demonstrate real innovation on the 
part of their own staff as well as on the part of the stakeholders they 
have brought together.
    Discussion: The Secretaries agree with the commenter that special 
consideration should be given to States that propose innovative 
approaches and have added this factor to the decision-making process of 
the Secretaries.
    Changes: The notice has been modified so that the description of 
the review process included under ``Selection Criteria for Evaluating 
Applications'' has been revised to state that final funding decisions 
made by the Secretaries will also include consideration of such factors 
as replicability, sustainability, and innovation. In addition, the 
``Management Plan'' criterion now asks the question ``Does the 
management plan include a process for incorporating methods to improve 
or redesign the implementation system based on program outcomes?''
    Comment: One commenter was concerned about special education 
students and expressed the belief that interagency data collection is 
essential for monitoring the success of special education programs and 
requested that the Secretaries add a question to read: ``Does the 
State's management plan include a system for interagency data 
collection?'' This commenter also requested the insertion of the word 
``cross-trained'' into the question on key personnel so that it would 
read ``Are key personnel under the plan cross-trained and qualified to 
perform * * *.'' This commenter believed that key personnel should be 
knowledgeable on both labor and educational issues.
    Discussion: The Secretaries agree that the provision of 
occupational and career development assistance as well as program 
information, guidance, and counseling, are all important aspects of 
School-to-Work Opportunities programs to be developed under the 
priority. However, the Secretaries believe that the importance of these 
is already provided for in the priority as written. While the 
Secretaries agree with the commenter that it would be beneficial for 
applicants to utilize key personnel who are knowledgeable of both the 
labor and educational components, the Secretaries do not think it 
advisable to prescribe the qualifications of key personnel. The 
Secretaries prefer to leave those decisions to the States.
    Changes: None.
    Comment: One commenter was concerned about the sufficiency of 
occupational and career information provided under School-to-Work 
Opportunities programs and suggested adding two questions to the 
``Management Plan'' criterion, to read: ``Does the State management 
plan adequately address the timely provision of accurate occupational 
and career information to school and program administrators, teachers 
and counselors, students and parents throughout the State?'' and ``Does 
the State management plan adequately address the need to provide career 
development assistance, guidance and counseling to students and parents 
in all parts of the State?''
    Discussion: The Secretaries have concluded that, since the 
implementation of School-to-Work Opportunities programs will be a joint 
effort involving coordination among Federal, State, and local entities, 
it is likely that effective methods to improve or redesign a project's 
implementation will be shared among these.
    Changes: None.

Selection Criteria--Distribution of Points

    Comment: One commenter questioned the distribution of points among 
the selection criteria and recommended that the points be redistributed 
with 20 points for the ``Comprehensive Statewide System'' criterion, 17 
points for the ``Collaboration and Involvement of Key Partners'' 
criterion, 17 points for the ``Resources'' criterion (particularly if 
the disadvantaged are to meet the same goals as other students), 17 
points for the ``Student Participation'' criterion, 17 points for the 
``Local Programs'' criterion, and 12 points for the ``Management Plan'' 
criterion. Another commenter concerned with special education students 
suggested that more points be awarded for the ``Local Programs'' 
selection criterion.
    Discussion: The Secretaries have given much consideration to the 
distribution of points among the selection criteria. They have 
concluded that the distribution provided for in the notice results in 
the most appropriate balance among the criteria.
    Changes: None.

Selection Criteria--General

    Comment: One commenter believed the notice must be strengthened to 
ensure that all youth receive the assistance and services they need to 
fully participate and succeed and processes are in place for 
identifying and addressing disparities in participation and success. 
The commenter recommended that the Secretaries add a selection factor 
that reads: ``Are there adequate State and local provisions to ensure 
equal access to all programs and program components; supplemental 
services and accommodations necessary for various students to 
participate and succeed; the collecting of disaggregated data on how 
well different groups are being served; and the taking of effective 
steps to remedy unequal participation or outcomes (based on data 
concerning how groups need to be served)?''
    Discussion: In reviewing applications under this competition, the 
Secretaries will seek to determine the extent to which applications 
propose realistic strategies and programs to ensure that ``all 
students'' have an opportunity to participate in the State's School-to-
Work Opportunities programs. In order to succeed in a School-to-Work 
Opportunities program, some students may need additional assistance. In 
this regard, the selection criterion ``Student Participation'' will be 
used to assess applicants' strategies for recognizing barriers to 
participation and proposing effective ways of overcoming them. However, 
the program funded under this competition does not purport to guarantee 
access to every student.
    Changes: None.
    Comment: One commenter suggested that the selection criteria 
consider the extent and quality of a State's implementation of key 
Perkins Act provisions, including all aspects of the industry, 
academic-vocational integration, full access, services and success for 
individuals who are members of special populations, and effective 
participatory planning with students, parents, teachers, and area 
residents in terms of: (a) the extent of the State's current 
implementation of those provisions, and (b) how they will be 
coordinated with and incorporated into the comprehensive school-to-work 
system. This commenter believed the individual States' track records in 
implementing these Perkins Act provisions would be good indicators of 
their capacities for commitments to high quality implementation of 
School-to-Work Opportunities systems.
    Discussion: Because the School-to-Work Opportunities system to be 
developed and implemented under the priority will involve the 
coordination of education and training resources of many different 
Federal, State, and private sources, the Secretaries believe that a 
State's track record in implementing Perkins Act provisions, while 
important, is only one of many critical factors that serve as 
indicators of commitment and ultimately contribute to a successful 
School-to-Work Opportunities system. The Secretaries do not believe 
that giving special emphasis to a State's implementation of provisions 
under the Perkins Act fosters the intent that States develop 
comprehensive School-to-Work Opportunities systems that incorporate the 
best practices and programs regardless of funding source.
    Changes: None.

[FR Doc. 94-2387 Filed 2-2-94; 8:45 am]
BILLING CODE 4000-01-P