Job Training Partnership Act: Labor Title IV Initiatives Could Improve
Relations With Native Americans (Letter Report, 03/04/94,
GAO/HEHS-94-67).

This report provides information on the Indian and Native American job
training program authorized under title IV of the Job Training
Partnership Act. The act targets a variety of economically disadvantaged
groups, including Native Americans, to receive employment-seeking skills
and job training services. GAO discusses (1) the history of the
relationship between the Labor Department and the Native American
community with respect to the program and (2) the extent to which the
act's funds are used to provide training services, one of four allowable
cost categories under that program. GAO also examines disagreements
between the Labor Department and Native Americans over proposed changes
to program regulations and the reasonableness of such changes.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  HEHS-94-67
     TITLE:  Job Training Partnership Act: Labor Title IV Initiatives 
             Could Improve Relations With Native Americans
      DATE:  03/04/94
   SUBJECT:  Native Americans
             Education or training
             Program evaluation
             Native American education
             Employment or training programs
             Funds management
             Disadvantaged persons
             Aid for training or employment
IDENTIFIER:  JTPA Indian and Native American Job Training Program
             Job Training Partnership Act Program
             
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Cover
================================================================ COVER


Report to Congressional Requesters

March 1994

JOB TRAINING PARTNERSHIP ACT -
LABOR TITLE IV INITIATIVES COULD
IMPROVE RELATIONS WITH NATIVE
AMERICANS

GAO/HEHS-94-67

Job Training Partnership Act


Abbreviations
=============================================================== ABBREV

  ETA - Employment and Training Administration
  JTPA - Job Training Partnership Act

Letter
=============================================================== LETTER


B-252704

March 4, 1994

The Honorable William D.  Ford
Chairman, Committee on Education and Labor
House of Representatives

The Honorable Pat Williams
Chairman, Subcommittee on Labor-Management Relations
Committee on Education and Labor
House of Representatives

This report responds to your request for information on the Indian
and Native American job training program authorized under title IV of
the Job Training Partnership Act (JTPA).  Specifically, we are
providing you with information on (1) the history of the relationship
between the Department of Labor and the Native American community
with respect to the Native American employment and training program
and (2) the extent to which JTPA funds are used to provide training
services, one of four allowable cost categories under that program. 
You also requested that we examine the points of disagreement between
the Department of Labor and Native Americans over proposed changes to
program regulations and the reasonableness of such changes.  Because
Labor recently agreed to withdraw the draft regulations, the specific
points of contention are no longer relevant and, therefore, not
addressed in this report. 

In carrying out our work, we met with officials from Labor having
responsibility for the Native American job training program.  We also
met with representatives of the JTPA Native American Programs
Advisory Committee (a committee of Native Americans established by
Labor to serve as the principal vehicle for consultation between
Native American JTPA grantees and Labor) and the Indian and Native
American Employment and Training Coalition (a private, nonprofit
organization that serves as an informal information network for
Native American grantees).  In addition, we visited 7 of the 182
Native American grantees to obtain local program information.  We
selected locations that provided geographic dispersion; variation in
type of grantees (reservation, urban, and rural); and variation in
amount of funds received from the $60 million program, which ranged
from $248,000 at one grantee to $1.2 million at another.  We also met
with representatives of three smaller grantees receiving less than
$200,000.  (See app.  I for a more detailed discussion of our scope
and methodology.)


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

The once cooperative relationship between Labor and the Native
American community with respect to the job training program for
Native Americans has deteriorated over the past decade.  The primary
factor cited by Native Americans as contributing to this
deterioration was Labor's lack of sensitivity to the unique situation
and needs of Native Americans.  Labor's attempts in the past year to
issue new regulations for this program brought to the forefront the
deterioration of their relationship from one of cooperation to one of
confrontation.  The Native American community believed that these
proposed program revisions were undertaken without the consultation
required under JTPA and that these changes would significantly alter
the nature and effectiveness of the program.  Furthermore, Native
Americans felt that the proposed changes were directed at correcting
unsubstantiated problems. 

Labor recently initiated a dialogue with representatives from the
Native American community to obtain their perspective on issues
confronting the Native American program and to establish a new
partnership.  Labor withdrew the planned program regulatory changes
and promised Native American representatives that Labor would (1)
work closely with Native American groups in developing legislatively
mandated changes and (2) base any additional changes on an
independent program evaluation after seeking Native American
collaboration and assistance in the evaluation. 

You also requested information on the amount of JTPA Native American
job training program funds being spent on training services.  Based
on our review of the program year\1 1991 expenditures for 7 of the
182 Native American program grantees, we determined that they spent,
on average, 40 percent of their funds for training activities.  The
remaining funds were spent on other allowable activities such as
program administration, work experience\2 and community service\3
activities, and participant support services.  Across the seven
grantees, the amount spent on training ranged from 14 to 61 percent
of their funds.  According to grantees, geographic isolation and poor
economic conditions play a part in determining how much of their
grant funds they spend on various program activities such as
classroom training, work experience, or support services. 


--------------------
\1 JTPA operates on a program year basis which begins on July 1 and
ends on June 30 of the following year.  A program year is designated
by the year in which it begins.  Thus, program year 1991 includes the
period July 1, 1991, to June 30, 1992. 

\2 Work experience provides short-term or part-time work designed to
develop good work habits and basic work skills. 

\3 Community service employment is the type of work normally provided
by state and local government and includes such fields as crime
prevention and control, trash removal, maintenance of parks and
streets, and conservation activities. 


   BACKGROUND
------------------------------------------------------------ Letter :2

JTPA provides employment-seeking skills and job training services to
economically disadvantaged adults and youth and certain other
individuals to enable them to enter the labor force.  The act
provides for such services under three separate titles.  Title II
serves economically disadvantaged adults and youth; title III serves
dislocated workers; and title IV serves special targeted groups,
including Native Americans, migrant and seasonal farmworkers, and
veterans.  For the most part, state and local entities administer
titles II and III, while the Department of Labor administers title
IV. 

Section 401 of title IV established an employment and training
program to serve Indians, Alaskan Natives, and Hawaiian Natives
(hereafter referred to collectively as Native Americans).  This
program was included under the Comprehensive Employment and Training
Act of 1973 and incorporated into JTPA in 1982.  The Congress
believed that such a program was essential to addressing the serious
unemployment and economic conditions affecting Native Americans. 
Under JTPA, Labor is to administer the program in a manner that
maximizes the government's commitment to support growth and
development as determined by representatives of the communities and
groups served. 

Native American employment and training programs are administered by
the Division of Indian and Native American Programs within the Office
of Special Targeted Programs, Employment and Training Administration
(ETA), Department of Labor.  However, other offices within ETA also
have responsibility for various aspects of the program.  In October
1988, Labor established the JTPA Native American Programs Advisory
Committee to provide advice on rules, regulations, and performance
standards developed for the Native American program under JTPA. 
Subsequently, the 1992 JTPA amendments established a Native American
Employment and Training Council, which replaced the Program Advisory
Committee, to advise Labor on a variety of activities affecting the
Native American program.  According to Labor, the Council has been
duly chartered and all of the members appointed are Native Americans. 

The 182 grantees approved by Labor provide employment and training
services to eligible Native Americans nationwide.  (See app.  II for
an overview of participants, services, and outcomes at the seven
local programs we visited.) During the past several years, the
program has been funded at about $60 million annually.  Funding for
individual grantees varies significantly, depending on the size of
the population served.  In 1992, individual grants ranged from about
$16,000 to the Metlakatla Indian community in Alaska to nearly $7
million to the Navajo tribe in Arizona.  Approximately half of the
Native American grantees received over $200,000. 


   HISTORY OF LABOR-NATIVE
   AMERICAN RELATIONSHIP
------------------------------------------------------------ Letter :3

Labor's new Assistant Secretary for Employment and Training recently
stated his intention to develop a relationship with the Native
American community that will be characterized by honesty, trust, and
open communication.  This is in marked contrast to the relationship
that evolved between Labor and the Native American community over the
past several years. 

A major factor in the deterioration of the Native American
relationship with Labor was the grantees' perception of Labor as
being dictatorial, patronizing, and insensitive to the unique needs
of Native Americans.  Furthermore, according to Native American
representatives, Labor's proposal to change program regulations after
enactment of the 1992 JTPA amendments exacerbated the situation. 
They stated that it was the first time in 20 years that Labor had
attempted to implement regulations without closely conferring with
grantees and permitting their review of the draft regulations at
every step of the process. 

The act requires Labor to consult with Native American
representatives prior to prescribing rules and regulations required
to meet the special circumstances under which the Native American
program operates.  Native Americans did not consider meetings held
with Labor officials to discuss draft regulatory changes to be
consultative because these discussions occurred after Labor had made
and cleared decisions.  In contrast, Native American representatives
pointed to a process carried out following the enactment of JTPA in
1982, whereby Labor and a group of Native American grantees sat
together to craft implementing regulations. 

Labor officials, on the other hand, believed that in recent years the
grantees were uncooperative and unreceptive to any program changes. 
Furthermore, they believed that they had complied with JTPA
requirements by discussing proposed changes at several meetings with
representatives of the JTPA Native American Programs Advisory
Committee and other Native American grantees. 

This poor relationship was a major impediment to getting new
regulations implemented for the Native American program.  While Labor
believed that the proposed changes were needed to improve program
quality and strengthen program accountability, the Native American
community distrusted Labor's motives for revising regulations and
were incensed about being excluded from the developmental process. 
According to several Native American representatives, if Labor had
presented the proposed changes in a different manner and worked with
Native American representatives, much of the antagonism could have
been avoided. 

From Labor's perspective, Labor patterned many of the proposed
changes after those legislatively mandated by the 1992 JTPA
amendments for title II.  Native Americans, however, questioned
Labor's attempts to make the two programs similar, insisting that if
the Congress wanted to impose the new title II requirements on the
Native American program, it would have done so in the 1992
amendments.  In addition, they questioned the appropriateness of
adopting requirements developed for title II without considering the
special circumstances and needs of Native Americans. 

In August 1993, we discussed the preliminary results of our study
with Labor officials.  Subsequently, Labor officials met with
representatives of the Native American community to "forge a new
partnership." At that meeting Labor pledged to withdraw all prior
versions of the draft regulations and promised that any new
regulations would be developed with the assistance of the Native
American community.  Further, Labor said it intends to launch an
independent evaluation in program year 1995 of the Indian and Native
American employment and training program and indicated it will seek
the Native American community's collaboration and assistance in this
evaluation.  Finally, Labor has also awarded a grant to a Native
American program grantee to assist in developing and testing an
electronic communications network that would permit grantees and
Council members to communicate instantly with Labor as well as with
each other. 


   NATIVE AMERICAN PROGRAM
   MANAGEMENT STRUCTURE
------------------------------------------------------------ Letter :4

Native American representatives contend that Labor's program
management is fragmented, creating confusion, frustration, and
administrative burdens.  Although Labor's Division of Indian and
Native American Programs has primary responsibility for the
administration of the Native American program, as many as eight other
offices within ETA also have responsibility for, and authority over,
various aspects of the program.  For example, four different offices
have some oversight and monitoring responsibility.  Furthermore, in
the view of Native American grantees, most individuals in these
offices have little knowledge about Native American culture and
programs. 

The Assistant Secretary for Employment and Training said he plans to
restructure the management of the Native American job training
program as required by the 1992 JTPA amendments.  The amendments
require Labor to designate "a single organizational unit that shall
have as its primary responsibility the administration of all Native
American programs authorized under this Act." The Assistant Secretary
stated at a September 1993 congressional hearing\4 that, in
designating such a unit, he intended to consolidate functions so that
the Native American community will have a single point of contact to
the extent practicable.  He is considering how best to structure such
a unit within ETA.  Native American grantees would like the single
organizational unit to be headed by a Native American or someone with
first-hand knowledge of Native American culture and programs. 
Furthermore, they would like the unit to report directly to the
Assistant Secretary for Employment and Training. 


--------------------
\4 Joint hearing before the Senate Committee on Indian Affairs and
the Subcommittee on Employment and Productivity, Senate Committee on
Labor and Human Resources, September 15, 1993. 


   TRAINING EXPENDITURES
------------------------------------------------------------ Letter :5

The amount of program year 1991 grant funds spent on training ranged
from 14 percent to 61 percent at the seven Native American grantees
we visited.  Grantees used the remainder for program administration
and other activities such as work experience, community service
employment, and supportive services.  Training expenditures also
varied within individual grantee programs, depending upon which
program costs were included in the training cost category.  Using the
current Native American job training program definition of allowable
costs chargeable to training, the seven grantees, on average, used
about 40 percent of program year 1991 expenditures for training
services.  Labor had proposed changing the definition of training for
the Native American program (modeled after the definition of training
costs specified in the 1992 JTPA amendments for the title II
program).  Using the proposed definition, about 65 percent of the
seven grantees' program year 1991 expenditures would have been for
training services.  The primary reason for the higher training
expenditures under the 1992 definition is the inclusion of costs
associated with work experience and community service employment as
allowable training costs.  (See app.  III for a detailed discussion
of the classification of training under the two definitions.)


   AGENCY AND OTHER COMMENTS AND
   OUR EVALUATION
------------------------------------------------------------ Letter :6

Labor provided written comments, dated January 10, 1994, on a draft
of this report (see app.  V).  Labor stated that our report was
somewhat subjective because Labor believed it was intended to present
the views of the Native American grantee community.  Our intention
was not to present only the grantees' views.  Rather, we intended to
provide a balanced representation of the history of the relationship
between Labor and the grantees from both perspectives, and we believe
that we have done so.  In so doing, we realize that the information
developed consisted, for the most part, of the subjective views and
perceptions of both groups. 

Labor also cited actions that it has undertaken or proposed since the
completion of our audit work in September 1993 to meet the
requirements of the Job Training Reform Amendments of 1992, and we
have included these in our report.  Labor indicated that the
assertion by Native American representatives that, in the past,
program officials reported directly to the Assistant Secretary, ETA,
was incorrect.  We modified the report to eliminate this
misconception. 

Labor was concerned as well that our sample of participants
terminating from the program was too limited to draw generalized
conclusions or to discern the quality or effectiveness of the
services provided.  We agree with Labor and never intended to
generalize the results from our seven site visits to the overall
program or to use them to assess program quality or effectiveness. 
Rather, the site visits were intended merely to illustrate how local
programs operate under varying circumstances.  We have modified the
report to clarify this point.  We would like to point out, however,
that the sample of terminees drawn at each site visited was a
statistically valid sample and, therefore, representative of that
site. 

We also obtained oral comments on our draft report from the Chair of
the Native American Employment and Training Council and her remarks
were incorporated, where appropriate. 


---------------------------------------------------------- Letter :6.1

We are sending copies of this report to other congressional
committees, the Secretary of Labor, and other interested parties. 

Should you have any questions or need additional information, please
contact me at (202) 512-7014.  Major contributors to this report are
listed in appendix VI. 

Linda G.  Morra
Director, Education and
 Employment Issues


SCOPE AND METHODOLOGY
=========================================================== Appendix I

We visited seven Native American grantees to obtain information on
(1) their relationship with the Department of Labor, (2) the
potential impact of draft regulations, and (3) the amount of funds
spent on training.  Those selected for site visits provided
geographic dispersion, represented various types of grantees
(reservation, urban, and rural), and varied in the amount of funds
provided by JTPA title IV in program year 1992.  Our sample was not
intended to be representative of the program as a whole but to
provide examples of how local programs operate under varying
circumstances. 

Employment and training services are provided to eligible Native
Americans nationwide by 182 grantees.  As shown in figure I.1, the
highest concentration of grantees are in Oklahoma, Arizona, New
Mexico, and Alaska.  Conversely, Georgia, Iowa, Indiana, Kentucky,
New Hampshire, and West Virginia did not have any grantees in 1992. 

   Figure I.1:  States Where
   Native American Program
   Grantees Are Located

   (See figure in printed
   edition.)


In selecting the grantees to be visited, we stratified the 182 Native
American grantees into four groups according to the amount of JTPA
title IV funds received in program year 1992, the most recent funding
allocation: 

1. Over $1 million (8 grantees)
2. $500,000 to $1 million (21 grantees)
3. $200,000 to $500,000 (59 grantees)
4. Under $200,000 (94 grantees)

We selected the seven grantees from among those receiving over
$200,000 and in proportion to the number of grantees in each strata. 
(See table I.1.) That is, because two-thirds of the grantees
receiving over $200,000 were in the third strata, we selected
two-thirds of our sites (five) from that list of grantees.  This
approach resulted in us selecting 1 grantee from the 8 who received
over $1 million; 1 from the 21 grantees who received between $500,000
and $1 million; and 5 from the 59 grantees who received between
$200,000 and $500,000. 



                          Table I.1
           
               Native American Program Grantees
                   Selected for Site Visits

                                           Program year 1992
                                               JTPA title IV
Grantee                   Location                     funds
------------------------  --------------  ------------------
Florida Governor's                                $1,245,565
 Council                   Tallahassee,
 on Indian Affairs         FL
Creek Nation of Oklahoma  Okmulgee, OK               600,669
Candelaria American                                  470,784
 Indian                    Ventura, CA
 Council
Tigua Indian Tribe        El Paso, TX                467,717
San Carlos Apache Tribe   San Carlos, AZ             319,753
Blackfeet Tribal                                     260,236
 Business                  Browning, MT
 Council
Mattaponi Pamunkey                                   248,137
 Monacan                   King William,
 Consortium                VA
------------------------------------------------------------
At each of the seven grantees, we met with program officials and
reviewed the files for all or a sample of participants terminating
(terminees) from the program in program year 1991 in order to gain a
better understanding of how Native American job training programs
serve their people.  Overall, we reviewed client files for 522 of the
667 terminees.  We also reviewed program year 1991 JTPA title IV
expenditures to determine how much of this money grantees spent for
training activities. 

In addition to performing detailed work at seven grantees, we also
met with representatives from three Native American grantees who
received less than $200,000 in program year 1992, to obtain the views
of smaller grantees.  (See table I.2.)



                          Table I.2
           
                Other Native American Grantees
                         Interviewed

                                           Program year 1992
                                               JTPA title IV
Grantee                   Location                     funds
------------------------  --------------  ------------------
St. Regis Mohawk Tribe    Hogansburg, NY            $173,281
Central Maine Indian
 Association, Inc.         Bangor, ME                 95,572
Seminole Tribe of         Hollywood, FL               70,343
 Florida
------------------------------------------------------------
We met with officials from the Department of Labor and with the Chair
and other members of the JTPA Native American Programs Advisory
Committee.  We also met with the Director of the Indian and Native
American Employment and Training Coalition, a private, nonprofit
information network linking Native American job training grantees. 

We did our work between April 1993 and September 1993 in accordance
with generally accepted government auditing standards. 


PARTICIPANTS, SERVICES, AND
OUTCOMES OF SEVEN NATIVE AMERICAN
GRANTEES
========================================================== Appendix II


   BACKGROUND
-------------------------------------------------------- Appendix II:1

The Congress established a separate employment and training program
for Native Americans under title IV of JTPA because of the serious
unemployment and economic conditions that exist among Native
Americans and the compelling need for such services by members of
this community.  Native Americans eligible for the program include
Indians, Alaskan Natives, and Hawaiian Natives who are economically
disadvantaged, unemployed, or underemployed. 

In 1990, the U.S.  Bureau of the Census estimated the Native American
population at nearly 2 million with Indians making up about 96
percent of that figure.  Reservation and trust lands account for
almost 2 percent of U.S.  land in the lower 48 states and, in 1990,
about one-third of the Indian population lived on these lands.  Life
on the reservation is much different from that experienced by the
mainstream population.  For example, the Bureau of Indian Affairs
estimated that in 1991 unemployment on reservations was 45 percent. 
Nationwide, the unemployment rate in 1991 was under 7 percent.  Half
of the reservation residents live in poverty--more than triple the
national rate.  In addition, Indians on reservations have poorer
health, shorter life expectancy, lower educational attainment, and
the highest alcoholism rate of any racial or ethnic group in the
United States. 


   OVERVIEW OF THE NATIVE AMERICAN
   PROGRAM AT SEVEN LOCATIONS
-------------------------------------------------------- Appendix II:2

As described in appendix I, we visited seven Native American grantees
and reviewed program records for a statistically valid sample of
program year 1991 terminees (see table II.1).  Our sample included
Indians from 48 different tribes plus Hawaiian Natives.  Grantees may
serve eligible Native Americans regardless of tribal affiliation or
membership in another Native American group. 



                          Table II.1
           
             Program Year 1991 Terminees at Seven
                       Grantees Visited

Grantee             Universe          Sample         Percent
------------  --------------  --------------  --------------
A                        136             103              76
B                         79              68              86
C                        210             137              65
D                         58              58             100
E                         32              32             100
F                        125              97              78
G                         27              27             100
============================================================
Total                    667             522              78
------------------------------------------------------------

   PARTICIPANT CHARACTERISTICS
-------------------------------------------------------- Appendix II:3

Overall, our sample of program year 1991 terminees from the seven
grantees visited showed that, on average,

  63 percent were adults (age 22 or older),

  53 percent were female,

  26 percent were school dropouts,

  86 percent were either unemployed or not in the labor force at the
     time of application,

  25 percent were receiving cash welfare,\1

  19 percent were single parents with a dependent child, and

  57 percent had at least one barrier to employment.\2

These characteristics varied substantially by grantee, as illustrated
in figures II.1 through II.7.  For example, at three grantees, less
than half the program year 1991 terminees in our sample were adults,
while at another grantee almost 90 percent were adults.  (See fig
II.1.)

   Figure II.1:  Percent of
   Terminees That Were Adults

   (See figure in printed
   edition.)

While not as dramatic, the range of female terminees in our sample
varied from about 44 percent at one grantee to about two-thirds at
another grantee.  (See fig.  II.2.)

   Figure II.2:  Percent of
   Terminees That Were Female

   (See figure in printed
   edition.)

As shown in figure II.3, the percent of program year 1991 terminees
in our sample that were school dropouts ranged from less than 10
percent at one location to almost half at another. 

   Figure II.3:  Percent of
   Terminees That Were School
   Dropouts

   (See figure in printed
   edition.)

The percentage of sampled terminees not working at the time of
application (either unemployed or not in the labor force) varied from
about two-thirds at one grantee to almost all at two other locations. 
(See fig.  II.4.)

   Figure II.4:  Percent of
   Terminees That Were Not Working
   at Time of Application

   (See figure in printed
   edition.)

While about one-fourth of the program year 1991 terminees in our
sample were receiving cash welfare when they applied to title IV for
assistance, the number ranged from a low of about 5 percent at two
grantees to about 60 percent at another location.  (See fig.  II.5.)

   Figure II.5:  Percent of
   Terminees That Were Receiving
   Cash Welfare

   (See figure in printed
   edition.)

As shown in figure II.6, sampled terminees who were single parents
with a dependent child ranged from 10 percent of the terminees at one
grantee to almost 40 percent of the terminees at another location. 

   Figure II.6:  Percent of
   Terminees That Were Single
   Parents With a Dependent Child

   (See figure in printed
   edition.)

On average, 57 percent of the program year 1991 terminees at the
seven locations we visited had at least one barrier to employment. 
This statistic is relevant because a point of controversy between
Labor and the Native American community involved Labor's draft
regulations, since withdrawn, which targeted program services to
participants who, in addition to being otherwise eligible for the
program, had to have at least one barrier to employment.  If this had
been required at the grantees we visited, over 40 percent of the
clients sampled would not have received services.  Native American
grantees stated that they believe the program was established to help
all eligible Native Americans, not just those with some arbitrary
barriers.  As shown in figure II.7, the percent of sampled terminees
having at least one barrier to employment varied significantly among
the grantees. 

   Figure II.7:  Percent of
   Terminees That Had at Least One
   Barrier to Employment

   (See figure in printed
   edition.)


--------------------
\1 We included recipients of Aid to Families with Dependent Children,
general relief, Supplemental Security Income, and Bureau of Indian
Affairs/tribal assistance in this category. 

\2 Barriers to employment as specified in the 1992 JTPA amendments
and Labor's draft regulations for the Native American program include
high school dropout, cash welfare recipient, deficient in basic
skills, substance abuser, disabled, homeless, offender, single parent
with a dependent child, displaced homemaker, or veteran. 


   SERVICES PROVIDED
-------------------------------------------------------- Appendix II:4

Native American program participants can receive a wide range of
services to help them overcome barriers to employment.  Allowable
services include basic education, occupational classroom training,
on-the-job training, work experience, community service employment,
job search assistance, and supportive services.  Our sample of
program year 1991 terminees showed that, on average, at the seven
locations we visited

  6 percent received basic education,

  29 percent received occupational classroom training,

  4 percent received on-the-job training,

  36 percent received work experience,

  12 percent received community service employment,

  19 percent received job search assistance as the only service, and

  19 percent received supportive services. 

As with participant characteristics, there were wide variances among
grantees in the kinds of services provided.  For example, while work
experience and occupational classroom training were the most
frequently used activities, significant variances existed among
grantees.  About 1 percent of the sampled terminees at one location
received work experience, whereas over 80 percent of the terminees at
two other grantees received this activity.  Similarly, at one grantee
3 percent of the terminees received occupational classroom training,
while at two other grantees over 60 percent received this training. 

On average, not many program year 1991 terminees in our sample
received basic education (6 percent), on-the-job training (4
percent), or community service employment (12 percent).  However,
some grantees provided these activities to a much greater extent. 
For example, one grantee provided basic education to 13 percent of
the terminees, another grantee provided on-the-job training to about
15 percent of its terminees, while over 30 percent of a third
grantee's terminees received community service employment. 

One controversial issue between Native American grantees and Labor
involved the proposed restriction on the use of job search assistance
as a stand-alone service.  While this was not an issue at three
grantees we visited, where no clients received only job search
assistance, at two other grantees it was the only service provided to
more than half of the terminees. 


   OUTCOMES ACHIEVED
-------------------------------------------------------- Appendix II:5

On average, about 61 percent of the program year 1991 terminees in
our sample obtained a job or had some other positive outcome upon
leaving the program.  About 46 percent obtained jobs; while another
15 percent had other positive outcomes, such as completing a major
level of education, returning to full-time school, entering the armed
forces, or enrolling in another training program not funded by title
IV.  (See fig.  II.8.)

   Figure II.8:  Program
   Performance

   (See figure in printed
   edition.)

As shown in figure II.9, the positive termination rate for program
year 1991 terminees at the seven grantees we visited ranged from 38
percent at one location to 85 percent at another. 

   Figure II.9:  Positive
   Termination Rate by Location

   (See figure in printed
   edition.)


AMOUNT OF JTPA FUNDS SPENT ON
TRAINING
========================================================= Appendix III

The amount of funds the seven grantees we visited were spending on
training varied depending on which one of two training definitions
was used.  Historically, Native American grantees have been able to
charge program expenditures to one of four cost categories: 
administration, training, employment (such as work experience and
community service employment), and other (including supportive
services).  Expenditures in the training category include costs
associated with

  classroom training;

  on-the-job training;

  participant allowances;

  books and related fees;

  instructor salaries;

  classroom equipment and supplies; and

  assessment, counseling, and job search assistance. 

Using this definition of allowable training costs, the seven grantees
spent, on average, about 40 percent of their total program year 1991
expenditures for training.  As shown in figure III.1, the amount
spent on training ranged from 14 percent at one location to about 60
percent at two others. 

   Figure III.1:  Percent of
   Expenditures Spent on Training
   Using the Existing Definition

   (See figure in printed
   edition.)

In the 1992 JTPA amendments, the Congress changed the definition of
training for title II.  Under the new definition, the training cost
category includes costs associated with work experience and excludes
costs associated with intake and job search assistance.  Labor's
draft regulations for the Native American program proposed making
these program costs consistent with the new title II definition of
training and included costs associated with community service
employment under the training category as well. 

Using this proposed definition of training, the seven grantees would
have spent, on average, about 65 percent of their funds on training. 
The proposed definition results in higher training expenditures
primarily because many Native American grantees provide work
experience and/or community service employment.  In some cases, the
amount of training expenditures was significantly higher under the
proposed definition.  For example, two grantees that had spent less
than 20 percent for training under the existing definition would have
spent over 70 percent if the proposed definition had been applied. 
Figure III.2 shows training expenditures for each of the seven
grantees using the existing and proposed definitions of training. 

   Figure III.2:  Comparison of
   Program Year 1991 Training
   Expenditures Using Existing and
   Proposed Definitions

   (See figure in printed
   edition.)

Grantees contend that training expenditures will vary because
participants have different program needs depending upon geographic
and economic conditions.  To meet the varying needs of their clients,
Native American grantees say they require the flexibility to
emphasize various program designs.  For example, one grantee, located
in the middle of the desert 120 miles from the nearest metropolitan
area, put 81 percent of its terminees in work experience because of
the lack of local employment opportunities.  Another grantee, whose
service area encompassed 400 miles of urban area, provided job search
assistance as the sole activity to about 60 percent of its terminees. 
According to the latter grantee director, a major reason for
emphasizing job search assistance was that the local Employment
Service office preferred to send all Indians to the Native American
program for assistance in finding jobs. 

The differences in training costs can also be affected by the length
of time clients receive services, as well as the intensity of those
services.  For example, one grantee enrolled 63 percent of its
terminees in 2-year associate degree programs at a local community
college because the grantee director did not believe in "quick-fix"
solutions.  Conversely, at another grantee, 55 percent of the
terminees received job search assistance as the only activity.  On
average, these participants were enrolled for less than a week. 


TABLES SUPPORTING BAR GRAPHS IN
REPORT TEXT
========================================================== Appendix IV



                          Table IV.1
           
            Percent of Terminees That Were Adults
                     (Data for fig. II.1)

Grantee                                 Percent of terminees
------------------------------  ----------------------------
A                                                         41
B                                                         76
C                                                         66
D                                                         88
E                                                         75
F                                                         49
G                                                         44
Average                                                   63
------------------------------------------------------------


                          Table IV.2
           
            Percent of Terminees That Were Female
                     (Data for fig. II.2)

Grantee                                 Percent of terminees
------------------------------  ----------------------------
A                                                         55
B                                                         56
C                                                         49
D                                                         67
E                                                         47
F                                                         55
G                                                         44
Average                                                   53
------------------------------------------------------------


                          Table IV.3
           
            Percent of Terminees That Were School
                Dropouts (Data for fig. II.3)

Grantee                                 Percent of terminees
------------------------------  ----------------------------
A                                                         20
B                                                         25
C                                                         26
D                                                         33
E                                                          9
F                                                         47
G                                                         19
Average                                                   26
------------------------------------------------------------


                          Table IV.4
           
              Percent of Terminees That Were Not
           Working at Time of Application (Data for
                          fig. II.4)

Grantee                                 Percent of terminees
------------------------------  ----------------------------
A                                                         66
B                                                         87
C                                                         85
D                                                         98
E                                                         97
F                                                         93
G                                                         74
Average                                                   86
------------------------------------------------------------


                          Table IV.5
           
           Percent of Terminees That Were Receiving
              Cash Welfare (Data for fig. II.5)

Grantee                                 Percent of terminees
------------------------------  ----------------------------
A                                                          6
B                                                         18
C                                                         24
D                                                         44
E                                                         59
F                                                         23
G                                                          4
Average                                                   25
------------------------------------------------------------


                          Table IV.6
           
            Percent of Terminees That Were Single
           Parents With a Dependent Child (Data for
                          fig. II.6)

Grantee                                 Percent of terminees
------------------------------  ----------------------------
A                                                         11
B                                                         16
C                                                         24
D                                                         39
E                                                         10
F                                                         17
G                                                         15
Average                                                   19
------------------------------------------------------------


                          Table IV.7
           
            Percent of Terminees That Had at Least
           One Barrier to Employment (Data for fig.
                            II.7)

Grantee                                 Percent of terminees
------------------------------  ----------------------------
A                                                         36
B                                                         60
C                                                         54
D                                                         71
E                                                         63
F                                                         73
G                                                         44
Average                                                   57
------------------------------------------------------------


                          Table IV.8
           
            Positive Termination Rate by Location
                     (Data for fig. II.9)


Grantee                              Job      Other positive
--------------------  ------------------  ------------------
A                                     32                  31
B                                     66                  12
C                                     67                  10
D                                     22                  16
E                                     47                   0
F                                     30                  10
G                                     59                  26
------------------------------------------------------------


                          Table IV.9
           
           Percent of Expenditures That Were Spent
                on Training Using the Existing
               Definition (Data for fig. III.1)

Grantee                              Percent of expenditures
------------------------------  ----------------------------
A                                                         60
B                                                         48
C                                                         61
D                                                         29
E                                                         17
F                                                         14
G                                                         50
Average                                                   40
------------------------------------------------------------


                         Table IV.10
           
             Comparison of Training Expenditures
           Using Existing and Proposed Definitions
                    (Data for fig. III.2)


                                Existing            Proposed
Grantee                       definition          definition
--------------------  ------------------  ------------------
A                                     60                  58
B                                     48                  55
C                                     61                  61
D                                     29                  61
E                                     17                  79
F                                     14                  70
G                                     50                  73
------------------------------------------------------------



(See figure in printed edition.)Appendix V
COMMENTS FROM THE DEPARTMENT OF
LABOR
========================================================== Appendix IV



(See figure in printed edition.)



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI

HEALTH, EDUCATION, AND HUMAN
SERVICES DIVISION,
WASHINGTON, D.C. 

Sigurd R.  Nilsen, Assistant Director for Education and Employment
Issues,
 (202) 512-7003
Thomas N.  Medvetz, Senior Evaluator

BOSTON REGIONAL OFFICE

Carol L.  Patey, Senior Evaluator
Wayne J.  Sylvia, Evaluator-in-Charge
Carlos J.  Evora, Evaluator

OFFICE OF THE GENERAL COUNSEL

Sylvia L.  Shanks
