Multiple Employment Training Programs: Conflicting Requirements Hamper
Delivery of Services (Letter Report, 01/28/94, GAO/HEHS-94-78).
Conflicting eligibility requirements and differences in annual operating
cycles are hampering federal employment training programs from helping
people in need of services. Differences in eligibility criteria, such
as income level, family or household definitions, and age, make
determining who is eligible for which program a complex process that
confuses clients and frustrates administrators. Within each target
group, differences in annual operating cycles also hinder the ability of
program administrators to cooperate to ensure that participants receive
the services they need. For example, the 16 programs that target youth
have four different operating cycles. One state administrator stated
the problem especially clearly: "The aim of case management is to assess
various programs in order to deliver the base services possible to
clients. However, conflicting requirements turn coordination into a
jigsaw puzzle."
--------------------------- Indexing Terms -----------------------------
REPORTNUM: HEHS-94-78
TITLE: Multiple Employment Training Programs: Conflicting
Requirements Hamper Delivery of Services
DATE: 01/28/94
SUBJECT: Employment or training programs
Program management
Eligibility determinations
Program evaluation
Aid for training or employment
Disadvantaged persons
Eligibility criteria
Federal aid programs
Income maintenance programs
IDENTIFIER: Aid to Families with Dependent Children Program
AFDC
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Cover
================================================================ COVER
Report to the Chairman, Subcommittee on Employment and Productivity,
Committee on Labor and Human Resources, U.S. Senate
January 1994
MULTIPLE EMPLOYMENT TRAINING
PROGRAMS - CONFLICTING
REQUIREMENTS HAMPER DELIVERY OF
SERVICES
GAO/HEHS-94-78
Multiple Employment Training Programs
Abbreviations
=============================================================== ABBREV
AFDC - Aid to Families With Dependent Children
EDWAA - Economic Dislocation and Worker Adjustment Assistance
IRS - Internal Revenue Service
JOBS - Job Opportunities and Basic Skills Training
JTPA - Job Training Partnership Act
OPM - Office of Personnel Management
LLSIL - Lower Living Standard Income Level
SCSEP - Senior Community Service Employment Program
SSI - Supplemental Security Income
TAA - Trade Adjustment Assistance
UI - Unemployment Insurance
Letter
=============================================================== LETTER
B-253138
January 28, 1994
The Honorable Paul Simon, Chairman
Subcommittee on Employment and Productivity
Committee on Labor and Human Resources
United States Senate
Dear Mr. Chairman:
For many years, administrators and clients have struggled to navigate
through the increasing multitude of federal employment training
programs. Our analysis of the President's proposed fiscal year 1994
budget identified at least 154 programs\1 that provide about $25
billion in funding for employment training assistance for adults and
out-of-school youth.\2 Many of the 154 programs provide similar or
complementary services to the same target populations. To promote
coordination among these programs, the Congress has required some
agencies to jointly plan their activities, and, in some instances,
has provided funding to facilitate coordination efforts. In
addition, several states have taken steps to better coordinate
service delivery at the local level. However, differences in program
requirements often hamper efforts to coordinate the delivery of
services to help people find jobs.
This report responds to your request that we identify how programs
serving the same target populations differ concerning (1) eligibility
requirements and (2) annual operating cycles.\3 Our review focused on
38 programs providing employment training assistance to four target
groups--economically disadvantaged, older, younger, and dislocated
workers--at a cost of $8.1 billion.\4 In our analysis of each
program, we reviewed the statutes, regulations, and agency documents.
We also held discussions with state and local administrators
regarding program requirements.
In addition to this report, we are issuing another report concerning
problems with the current fragmented "system" of multiple employment
training programs. That report, Multiple Employment Training
Programs: Overlapping Programs Can Add Unnecessary Administrative
Costs (GAO/HEHS-94-80, Jan. 28, 1994), concerns the extent to which
programs overlap in the populations they target, in the services they
provide, and in the administrative structures they create to deliver
those services. We also have other ongoing work that (1) concerns
the extent to which federal agencies know whether their employment
training programs are effective in helping participants compete in
the workforce and (2) addresses the need for a major overhaul of the
entire federal employment training system.
--------------------
\1 As used in this report, "employment training program" refers to
those programs and related funding streams that provide assistance to
adults and out-of-school youth that enhances individual skills or
employment opportunities. Appendix I lists each of the 154 programs
and their proposed funding for fiscal year 1994.
\2 Multiple Employment Programs: National Employment Training
Strategy Needed (GAO/T-HRD-93-27, June 18, 1993).
\3 The original request asked that we also look at differences in
performance measures; however, because of the limited number of
programs with specific performance measure definitions, it was agreed
that we would drop this issue from our analysis.
\4 Appendix II shows the 38 programs by target population and their
proposed funding levels for fiscal year 1994.
BACKGROUND
------------------------------------------------------------ Letter :1
In 1992, at least 9.4 million people of work age were unemployed
during some part of the year. At the same time, others were trying
to enter the workforce for the first time. While many of these
people were successful at finding jobs, others had more difficulty.
Among those groups with the highest unemployment were youth, with an
unemployment rate almost three times the national average. On
average, over 1.3 million youth between the ages of 16 and 19 were
unemployed each month in 1992. Large numbers of economically
disadvantaged workers also had difficulty finding jobs. Of the 4.8
million families on Aid to Families With Dependent Children (AFDC)
each month, about 8 percent of the adults worked in 1992. Other
groups, such as Native Americans, migrants, and older workers, also
had a difficult time finding a job.
To help people from these groups find a place in the workforce, the
federal government has created a variety of programs. Many of these
programs target the same populations. Our work identified 10 groups
that were the focus of most federal employment training programs--
economically disadvantaged, older workers, youth, dislocated workers,
Native Americans, refugees, migrants, the homeless, women and
minorities, and veterans.
These programs often provide the same target population similar or
complementary services in the same five basic areas: (1) counseling
and assessment, (2) remedial education, (3) vocational skills
training, (4) placement assistance, and (5) support services. To
make the most of the limited resources available in each program, it
is important that these programs work together as they deliver
services at the local level.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :2
Conflicting eligibility requirements and differences in annual
operating cycles are hampering the ability of programs to provide
participants needed services. Despite decades of efforts to better
coordinate employment training programs, conflicting requirements
continue to make it difficult for program staff to coordinate
activities and share resources. One state administrator stated the
problem especially clearly: "The aim of case management is to access
various programs in order to deliver the best services possible to
clients. However, conflicting requirements turn coordination into a
jigsaw puzzle...."
Differences in eligibility criteria make determining who is eligible
for which program a complex process that confuses clients and
frustrates administrators. For example, the nine programs targeting
the economically disadvantaged use several different standards for
measuring income level, for defining family or household, and for
defining what is included in income. Programs targeting older
workers create confusion because they use differing age requirements
to define "older worker." Programs targeting youth differ in age
criteria at both the lower age limit and the upper age limit.
Dislocated worker programs differ in their criteria for what
constitutes an eligible "job loss" such as in the recognition of
pending layoff notices, definitions of dates of employment, voluntary
separations, and reduced hours or wages.
Within each target group, differences in annual operating cycles also
hamper the ability of program administrators to plan together to
ensure that participants receive the services they need. For
example, the 16 programs that target youth have four different
operating cycles. Some programs serving the same target population
will have completed their planning process and begun operation on
January 1, while other programs will not complete their planning
until the following July. As a result, administrators may not be
able to coordinate their plans to ensure that the resources needed to
serve their clients are available.
DIFFERENCES IN ELIGIBILITY
CRITERIA HAMPER DELIVERY OF
SERVICES
------------------------------------------------------------ Letter :3
Reconciling definitions for eligibility among programs attempting to
serve the same target populations can help programs share resources
and coordinate activities. However, we found significant differences
in the eligibility criteria in each of the four target groups we
analyzed. For example, not all programs targeting the economically
disadvantaged used the same definition of "economically
disadvantaged." We found that six different standards were used for
defining income eligibility levels, five for defining family or
household, and five for defining what is included in income. As a
result, a member of a family of four with an income of $20,040 would
be considered "disadvantaged" and eligible for services from one
program, but the same $20,040 income exceeds another program's
definition of "disadvantaged," making the family member ineligible
for services from that program. With the need for programs to be
able to share resources to meet all their clients' needs, this could
mean that some clients may not be able to obtain needed services.
See appendix III for more information on the different standards used
in each of the programs that targeted the economically disadvantaged.
Given the confusion created by the differing eligibility
requirements, it is not surprising that a recent survey of state and
local administrators showed that administrators frequently
recommended standardizing the term "economically disadvantaged." Most
of those surveyed wanted to standardize all terms related to income
definitions, such as what constitutes family income or personal
income, how to establish ownership of resources, and what is included
in income disregards. One benefit that the administrators felt could
be achieved by developing standard definitions and criteria was that
the same intake form could be used across programs, which would
facilitate coordination efforts and improve service delivery.\5
Income criteria are not the only eligibility concern. Programs
targeting older workers differ in how they define "older worker."
Some used a minimum age of 55 years, while others used a minimum of
60 years. Programs targeting youth also differ in their age limits.
Lower age limits for youth programs ranged from 11 to 16 years of
age, while upper age limits ranged from 19 to 27. See appendixes IV
and V, respectively, for more information on the age criteria used by
older worker programs and youth programs. As mentioned earlier,
dislocated worker programs differ in their criteria for what
constitutes an eligible "job loss." See appendix VI for more
information on each program's definition of what constitutes a job
loss. These differences, according to state and local
administrators, not only make it difficult for case managers to
determine eligibility of clients, but clients themselves feel
confused and discriminated against.
--------------------
\5 Streamlining and Integrating Human Resource Development Services
for Adults, National Governors' Association, Training and Employment
Program (Center for Policy Research, 1991).
DIFFERENCES IN OPERATING CYCLES
ALSO HAMPER COORDINATION
------------------------------------------------------------ Letter :4
Differences in program operating cycles also make it difficult for
administrators attempting to coordinate their programs through joint
planning. Matching available funding with estimates of the number of
those seeking assistance is more complex, if not impossible, when
operating cycles do not match. However, as shown in figure 1, we
found that programs within each of the four target groups operate on
different annual cycles. Most programs (20) operated on the basis of
a program year (July 1-June 30); 12 programs operated on the federal
fiscal year (October 1-September 30); 4 programs operated on an
academic year (September 1-August 31); and 2 programs operated on a
calendar year (January 1-December 31). See appendix VII for more
information on the operating cycles for each program in our analysis.
Figure 1: Programs Differ in
Definition of Annual Operating
Cycle
(See figure in printed
edition.)
This problem is compounded for program administrators who need to
integrate program operating cycles into state and local operating
time frames. One state administrator, for example, indicated that
his state operates on a September to August time frame, while some
federal programs operate on the federal fiscal year (October 1 to
September 30), and others operate on a program year (July 1 to June
30).
To accomplish joint planning, agencies must resort to several
circuitous strategies. According to local administrators, some
officials set low estimates of the number of clients from other
programs they can serve or others only commit resources they know
will be available but contribute additional resources if they become
available at a later time. Other agencies make such commitments
contingent on expected funding so they are not held to prior
commitments when their expected funding levels are not realized.
Unfortunately, these methods can result in the underutilization of
available resources or crisis planning when resources are available.
CONCLUSION
------------------------------------------------------------ Letter :5
Programs are increasingly being directed to coordinate activities and
share resources to ensure that anyone who needs help can get it.
Nevertheless, program administrators, as well as those people needing
employment training assistance, continue to face a fragmented
"system" of categorical programs characterized by differences in
eligibility requirements and annual operating cycles. Differences in
eligibility criteria and operating cycles among programs serving the
same target populations act as barriers to coordinating program
services and impede the effective delivery of needed services and the
efficient use of program resources. As a result, people in need of
employment training assistance may not have access to the services
they need to help them find jobs.
Our work was conducted between April and September 1993 in accordance
with generally accepted government auditing standards. As you
requested, agency comments on this report were not obtained, but
copies will be sent to those involved and other interested parties.
Should you have any questions or wish to discuss the information
provided, please call me at (202) 512-7014. Other major contributors
are listed in appendix VIII.
Sincerely yours,
Linda G. Morra
Director, Education
and Employment Issues
FEDERAL EMPLOYMENT AND TRAINING
PROGRAMS PROPOSED FUNDING LEVELS
BY AGENCY (FISCAL YEAR 1994)\A
=========================================================== Appendix I
(Dollars in millions)
Agency and programs Fiscal year 1994\b
------------------------------------------------------------ ------------------
================================================================================
All programs (154) Total: $24,837.7
Action -(3) programs Total: 100.9
Literacy Corps 5.3
Foster Grandparent Program 66.4\c
Senior Companion Program 29.2\c
Department of Agriculture -(1) program Total: 162.7
Food Stamp Employment & Training 162.7\c
Appalachian Regional Commission -(1) program Total: 11.2
Appalachian Vocational and Other Education Facilities and 11.2
Operations
Department of Commerce -(9) programs Total: 220.5
Minority Business Development Centers 24.4
American Indian Program 1.9
Economic Development-Grants for Public Works and Development 135.4
Economic Development-Public Works Impact Program \d
Economic Development-Support for Planning Organizations 24.8
Economic Development-Technical Assistance 10.4
Economic Development-State and Local Economic Development 4.5
Planning
Special Economic Development and Adjustment Assistance 19.1
Program-Sudden and Severe Economic Dislocation and Long-
Term Economic Deterioration
Community Economic Adjustment \e
Department of Defense -(2) programs Total: 72.8
Military Base Reuse Studies and Community Planning 6.0
Assistance
Transition Assistance Program 66.8\c
Department of Education -(60) programs Total: 13,031.4
Even Start-State Educational Agencies 88.8
Even Start-Migrant Education 2.7
Women's Educational Equity 2.0
Indian Education-Adult Education 4.9
Migrant Education-High School Equivalency Program 8.1
Migrant Education-College Assistance Migrant Program 2.3
School Dropout Demonstration Assistance 37.7\c
Adult Education-State Administered Basic Grant Program 261.5
Adult Education for the Homeless 10.0
National Adult Education Discretionary Program 9.3
Vocational Education-Demonstration Projects for the \f
Integration of Vocational and Academic Learning
Vocational Education-Educational Programs for Federal \f
Correctional Institutions
Vocational Education-Comprehensive Career Guidance and \f
Counseling
Vocational Education-Blue Ribbon Vocational Educational \f
Programs
Vocational Education-Model Programs for Regional Training \f
for Skilled Trades
Vocational Education-Business/Education/Labor Partnerships \f
Vocational Education-Tribally Controlled Postsecondary 2.9
Vocational Institutions
Vocational Education-Tribal Economic Development \f
Vocational Education-Basic State Programs 717.5\c
Vocational Education-State Programs and Activities 81.3
Vocational Education-Single Parents, Displaced Homemakers, 69.4
and Single Pregnant Women
Vocational Education for Sex Equity 31.1
Vocational Education-Programs for Criminal Offenders 9.6
Vocational Education-Cooperative Demonstration \f
Vocational Education-Indian and Hawaiian Natives 15.1
Vocational Education-Opportunities for Indians and Alaskan \f
Natives
Vocational Education-Community Based Organizations 11.8\c
Vocational Education-Bilingual Vocational Training 0.0
Vocational Education-Demonstration Centers for the Training
of Dislocated Workers
Vocational Education-Consumer and Homemaking Education 0.0
Vocational Education-TechPrep Education 104.1
National Workplace Literacy Program 22.0
English Literacy Program 0.0
Literacy for Incarcerated Adults 5.1
National Center for Deaf-Blind Youth and Adults 6.7
State Literacy Resource Centers 7.9
Student Literacy Corps 6.1\c
Federal Pell Grant Program\g 2,846.9
Guaranteed Student Loans\g 5,889.0
Federal Supplemental Education Opportunity Grants\g 125.0
Upward Bound 160.5\c
Talent Search 67.0\c
Federal Work Study Program\g 89.6
Federal Perkins Loan Program-Federal Capital Contributions\g 13.0
Grants to States for State Student Incentives 0.0
Educational Opportunity Centers 23.3\c
Higher Education-Veterans Education Outreach Program 3.1
Student Support Services 110.3
Postsecondary Education Programs for Persons with 8.8
Disabilities
Rehabilitation Services Basic Support-Grants to States 1,933.4
Rehabilitation Services Basic Support-Grants for Indians 6.4
Rehabilitation Services Service Projects-Handicapped 1.2
Migratory and Seasonal Farm Workers
Rehabilitation Services Service Projects-Special Projects 19.9
and Demonstrations for Providing Vocational Rehabilitation
Services to Individuals With Severe Disabilities
Rehabilitation Services Service Projects-Supported 10.6
Employment
Projects With Industry Programs 21.6
Supported Employment Services for Individuals with Severe 33.1
Handicaps
Comprehensive Services for Independent Living 15.8
Library Literacy 0.0
School to Work\h 135.0\c
Public Library Services \f
Department of Health and Human Services -(14) programs Total: 2,203.5
Job Opportunities and Basic Skills Program 825.0\c
Community Services Block Grant 352.7
Community Services Block Grant-Discretionary Award 39.7
Community Services Block Grant Discretionary Awards- 4.4
Demonstration Partnership
Refugee and Entrant Assistance-Discretionary Grants 12.6
Refugee and Entrant Assistance-State Administered Programs 84.4
Refugee and Entrant Assistance-Voluntary Agency Programs 39.9
Community Demonstration Grant Projects for Alcohol and Drug \f
Abuse Treatment of Homeless Individuals
Family Support Centers Demonstration Program 6.9
State Legalization Impact Assistance Grants 809.9
Transitional Living for Runaway and Homeless Youth 11.8\c
Independent Living 16.2\c
Scholarships for Health Professions Students From \f
Disadvantaged Backgrounds
Health Careers Opportunity Program \f
Department of Housing and Urban Development -(4) programs Total: 303.4
Emergency Shelter Grants Program 51.4
Supportive Housing Demonstration Program 164.0
Youthbuild\h 88.0\c
Family Self-Sufficiency Program \c,j
Department of the Interior -(2) programs Total: 20.9
Indian Employment Assistance 16.9
Indian Grants-Economic Development 4.0
Department of Labor -(36) programs Total: 7,141.5
JTPA IIA Training Services for the Disadvantaged-Adult 793.1\c
JTPA IIA State Education Programs 82.4\c
JTPA IIA Incentive Grants 51.5\c
JTPA IIA Training Programs for Older Individuals 51.5\c
JTPA IIC Disadvantaged Youth 563.1\c
JTPA IIC Disadvantaged Youth-Incentive Grants 34.3\c
JTPA IIC Disadvantaged Youth-State Education Programs 54.9\c
JTPA IIB Training Services for the Disadvantaged-Summer 1,688.8\c
Youth Employment and Training Program (Regular)
JTPA IIB Summer Youth Employment and Training Program \b,k
(Native American)
JTPA EDWAA-Dislocated Workers (Local SDA Allotment)\k 229.5\c
JTPA EDWAA-Dislocated Workers (Governor's 50% 229.5\c
Discretionary)\k
JTPA EDWAA-Dislocated Workers (Secretary 20% 114.7\c
Discretionary)\k
JTPA Defense Conversion Adjustment Program \c,m
JTPA Defense Diversification \c,n
JTPA Clean Air Employment Transition Assistance \c,o
JTPA-Migrant and Seasonal Farmworkers 78.3
JTPA-Employment and Training Research and Development 11.2
Projects
JTPA Employment Services and Job Training-Pilot and 35.1
Demonstration Programs
JTPA-Native American Employment and Training Programs 61.9
JTPA Job Corps 1,153.7\c
Federal Bonding Program 0.2
Senior Community Service Employment Program 421.1\c
Apprenticeship Training 17.2
Trade Adjustment Assistance-Workers 215.0\c
Targeted Jobs Tax Credit 19.2
Employment Service-Wagner Peyser State Grants (7a) 734.8
Employment Service-Wagner Peyser Governor's Discretionary 81.6
Funds (7b)
Labor Certification for Alien Workers 58.6
Interstate Job Bank 1.9
Youth Fair Chance\i 25.0\c
One-Stop Career Centers\i 150.0
Veterans Employment Program 9.0
Disabled Veterans Outreach Program 84.0
Local Veterans Employment Representative Program 77.9
Homeless Veterans Reintegration Project \f
Job Training for the Homeless Demonstration Project 12.5
Office of Personnel Management -(1) program Total: \q
Federal Employment for Disadvantaged Youth-Summer \c,q
Small Business Administration -(8) programs Total: 157.4
Management and Technical Assistance for Socially and 8.1
Economically Disadvantaged Businesses
Small Business Development Center 67.0
Women's Business Ownership Assistance 1.5
Veteran Entrepreneurial Training and Counseling 0.4
Service Corps of Retired Executives Association 3.1
Business Development Assistance to Small Business 20.9
Procurement Assistance to Small Business 33.7
Minority Business Development 22.7
Department of Transportation -(1) program Total: 1.5
Human Resource Programs 1.5
Department of Veterans Affairs -(12) programs Total: 1,410.0
All-Volunteer Force Educational Assistance 895.1
Selected Reserve Educational Assistance Program \t
Survivors and Dependents Educational Assistance 109.1
Vocational Rehabilitation for Disabled Veterans 245.1
Post-Vietnam Era Veterans Educational Assistance 42.4
Hostage Relief Act Program \s
Vocational Training for Certain Veterans Receiving VA \f
Pension
Vocational and Educational Counseling for Servicemembers and \t
Veterans
Service Members Occupational Conversion and Training 64.5
Health Care for Homeless Veterans 28.3
Domiciliary Care for Homeless Veterans 23.4
Housing and Urban Development/Veterans Affairs-Supported 2.1
Housing
--------------------------------------------------------------------------------
\a Programs identified are federally funded and designed to (1)
assist the unemployed, (2) create employment, and (3) enhance
employability. The programs provide assistance to adults and
out-of-school youth not enrolled in advanced-degree programs.
\b The proposed fiscal year 1994 funding amounts shown in appendix I
are based primarily on the President's proposed budget dated April 8,
1993. In some instances, the amount shown may have been adjusted to
reflect only that portion of the program that provided assistance to
adults and out-of-school youth; however, in other instances the
amount shown is for the entire program even though only a portion of
the program funding may go to providing employment training
assistance as defined in this report.
\c Program included in analysis.
\d Economic Development-Public Works Impact: program funds included
in Grants for Public Works and Development Facilities.
\e Community Economic Adjustment: funds allocated in 1993 are used
to support programs in out years until funding is depleted.
\f Data not available at this time.
\g Education loan program: amounts shown are estimates of loans for
associate and nondegree programs, when possible to differentiate.
\h School to Work: program proposed for fiscal year 1994. Funded at
$270.0 million split evenly between the Departments of Education and
Labor. Department of Education funding is from Carl Perkins Act:
$15 million from National Programs-Research and Development and $120
million from Cooperative Demonstrations Program. Department of Labor
funding is from the Job Training Partnership Act (JTPA).
\i Youthbuild: program proposed for fiscal year 1994.
\j Family Self-Sufficiency Program: job training, education, and
support services are paid for by other programs such as Job
Opportunities and Basic Skills Training (JOBS) and JTPA. Federal
funds may be used to cover local administrative costs. For fiscal
year 1993, appropriations for operating subsidies permit the payment
of $25.9 million to cover the administrative costs of operating the
Family Self-Sufficiency program.
\k The actual funding for the JPTA Title III EDWAA program was
increased significantly from the budget request dated April 8, 1993.
The proposed funding for substate areas of $229.5 million was
increased to $537 million. The proposed funding for the EDWAA
Governor's Discretionary funds were also $229.5 million, but was
increased to $357 million. Similarly, the Secretary's Discretionary
funds were increased from $114.7 million to $223 million.
\l JTPA IIB Summer Youth Employment and Training Program (Native
American): funding included in JTPA IIB (Regular) program total.
\m JTPA Defense Conversion Adjustment Program: funds allocated in
1991 used to support programs in out years until funding is depleted.
\n JTPA Defense Diversification: funds allocated in 1993 used to
support programs in out years until funding is depleted.
\o JTPA Clean Air Employment Transition Assistance: no funds were
appropriated for the Clean Air Act in fiscal year 1994.
\p New program in 1994.
\q Federal Employment for Disadvantaged Youth-Summer: program
coordinated by Office of Personnel Management (OPM), but carried out
by numerous federal agencies. Obligations devoted to administration
not separately identifiable.
\r Selected Reserve Educational Assistance Program: funding included
in All-Volunteer Force Educational Assistance total.
\s Hostage Relief Act Program: replaced by the Omnibus Diplomatic
Security and Anti-Terrorist Act of 1986. No program funding used in
any year, but available.
\t Vocational and Educational Counseling for Servicemembers and
Veterans: program funds included in other veterans programs, such as
the All-Volunteer Force Educational Assistance Program.
FOUR TARGET GROUPS INCLUDED IN
ANALYSIS
========================================================== Appendix II
Fiscal year
1994 proposed
funding (in
Target group Program millions)
---------------------- ---------------------------------------- --------------
Economically JTPA IIA Training Services for the $ 793.1
Disadvantaged Disadvantaged-Adult
JTPA IIA State Education Programs 82.4
JTPA IIA Incentive Grants 51.5
Job Opportunities and Basic Skills 825.0
Training
Food Stamp Employment and Training 162.7
Family Self-Sufficiency Program \a
Vocational Education-Basic State 717.5
Programs
Educational Opportunity Centers 23.3
Student Literacy Corps 6.1
================================================================================
Subtotal 2,661.6
Older Workers Senior Community Service Employment 421.1
Program
JTPA IIA Training Program for Older 51.5
Individuals
Foster Grandparent Program 66.4
Senior Companion Program 29.2
================================================================================
Subtotal 568.2
Youth JTPA IIC Disadvantaged Youth 563.1
JTPA IIC Disadvantaged Youth -Incentive 34.3
Grants
JTPA IIC Disadvantaged Youth -State 54.9
Education Programs
JTPA IIB Training Services for the 1,688.8
Disadvantaged-Summer Youth Employment
and Training Program (Regular)
JTPA IIB Summer Youth Employment and \b
Training Program (Native American)
JTPA Job Corps 1,153.7
Youth Fair Chance 25.0
Transitional Living for Runaway and 11.8
Homeless Youth
Independent Living 16.2
School Dropout Demonstration Assistance 37.7
Vocational Education-Community Based 11.8
Organizations
Upward Bound 160.5
Talent Search 67.0
School to Work 135.0
Federal Employment for Disadvantaged \c
Youth-Summer
Youthbuild 88.0
================================================================================
Subtotal 4,047.8
Dislocated Workers JTPA EDWAA-Dislocated Workers (Local SDA 229.5
Allotment)
JTPA EDWAA-Dislocated Workers 229.5
(Governor's 50% Discretionary)
JTPA EDWAA-Dislocated Workers 114.7
(Secretary's 20% Discretionary)
JTPA Defense Conversion Adjustment \d
Program
JTPA Clean Air Employment Transition \e
Assistance
JTPA Defense Diversification \f
Trade Adjustment Assistance-Workers 215.0
Vocational Education-Demonstration \g
Centers for the Retraining of
Dislocated Workers
Transition Assistance Program 66.8
================================================================================
Subtotal 855.5
================================================================================
Total for Target $8,133.1
Groups Analyzed
--------------------------------------------------------------------------------
\a Family Self-Sufficiency Program: job training, education, and
support services are paid for by other programs such as JOBS and
JTPA. Federal funds may be used to cover local administrative costs.
For fiscal year 1993, appropriations for operating subsidies permit
the payment of $25.9 million to cover the administrative costs of
operating the Family Self-Sufficiency program.
\b JTPA IIB Summer Youth Employment and Training Program (Native
American): funding included in JTPA IIB (Regular) program total.
\c Federal Employment for Disadvantaged Youth-Summer: program
coordinated by OPM, but carried out by numerous federal agencies.
Obligations devoted to administration not separately identifiable.
\d JTPA Defense Conversion Adjustment Program: funds allocated in
1991 used to support programs in out years until funding is depleted.
\e JTPA Clean Air Employment Transition Assistance: funds allocated
in 1993 used to support programs in out years until funding is
depleted.
\f JTPA Defense Diversification: funds allocated in 1993 used to
support programs in out years until funding is depleted.
\g Data not available at this time.
ELIGIBILITY STANDARDS FOR THE
ECONOMICALLY DISADVANTAGED
========================================================= Appendix III
In reviewing the factors generally used to determine eligibility, we
found that the nine programs that specifically target the
economically disadvantaged used six different measures of income
level, five definitions of family or household, and five definitions
of income. The large array of eligibility criteria makes
implementation difficult for state administrators as well as for
those seeking assistance.
As shown in table III.1, the standards used to measure low income
included the official poverty income guidelines, some multiple of
those guidelines (such as 130 or 150 percent), and area median family
income. Two programs illustrate the differences that can result from
using a variety of measures. A member of a family of four with an
income of up to $20,040 would be considered "disadvantaged" and
eligible for services from the Educational Opportunity Centers. This
program uses the income measure of 150 percent of the Bureau of
Census poverty level. However, for this same family member to be
eligible for the Food Stamp Employment and Training Program, income
could not exceed $17,420 because this program uses the measure of 130
percent of the official poverty guidelines. Some programs use two
measures. For example, JTPA programs use the higher of the official
poverty measure or 70 percent of the regionally adjusted Lower Living
Standard Income Level (LLSIL). In the above example, this would have
been the LLSIL, which was higher in the metropolitan Northeast,
$16,360, compared with $13,400 for the official poverty measure.
Table III.1
Different Standards for Measuring Income
Used by Programs Targeting Economically
Disadvantaged
Area
Median
Family
Program 100% 130% 70% Income 100% 150%
-------------------- -------- -------- -------- -------- -------- --------
JTPA IIA X\a X
Disadvantaged Adults
JTPA IIA State X X
Education Programs
JTPA IIA Incentive X X
Grants
Job Opportunities
and Basic Skills\b
Food Stamp X\c X
Employment and
Training
Family Self- X\d
Sufficiency Program
Educational X
Opportunity Centers
Vocational X\e X
Education-Basic
State Programs
Student Literacy
Corps\f
--------------------------------------------------------------------------------
\a JTPA programs base eligibility on whichever is higher, the
official poverty guidelines or 70 percent of the regionally adjusted
Lower Living Standard Income Level.
\b Eligibility varies by state because of differences in state
criteria for AFDC eligibility.
\c Uses three measures: (1) household income after exclusions and
deductions as defined by the Gross Income Standard for households
that include an elderly or disabled member or (2) household income
after exclusions but before deductions for households that do not
include an elderly or disabled member or (3) gross income not to
exceed 130 percent of the official poverty guidelines for households
that do not include an elderly or disabled member.
\d Uses two measures: "Low-income" does not exceed 80 percent of
area's median income while "very low income" does not exceed 50
percent of the area's median income.
\e This program allows educational institutions to use several
low-income measures as well as "other indices of economic status"
with the approval of the Department of Education.
\f While program is targeted to the economically disadvantaged, the
program requirements do not include a specific definition of income
or related financial eligibility information.
Program eligibility and coverage also depends on whose income is
counted in the eligibility calculation. We found five different
criteria for family or household. As shown in table III.2, for
example, JTPA considers the income of the family--all persons related
by blood, marriage, or court decree--in determining eligibility. In
contrast, the Food Stamp Program considers the income of the
household, all those who purchase and cook food together.
Table III.2
Different Standards for Defining a
Family or Household Used by Programs
Targeting Economically Disadvantaged
Persons
related by Other
blood, Unrelated unrelated Those who Unrelated
marriage, dependents persons if purchase & if elderly
or court of head of needed by cook food also
Program decree household child together present
-------------------- ---------- ---------- ---------- ---------- ----------
JTPA IIA Training X
Services for the
Disadvantaged-Adult
JTPA IIA State X
Education Programs
JTPA IIA Incentive X
Grants
Job Opportunities X
and Basic Skills
Training
Food Stamp X
Employment and
Training
Family Self- X
Sufficiency Program
Educational X
Opportunity Centers
Vocational
Education-Basic
State Programs\a
Student Literacy
Corps\b
--------------------------------------------------------------------------------
\a Complex family or household assistance unit definitions, which can
vary by state.
\b Family or household not defined.
Programs also differ in their definition of what constitutes income.
We identified five definitions of income, each with its own set of
deductions and exclusions (see table III.3). For example, the JTPA
programs include all earned income, but exclude unemployment
insurance. The Food Stamp Employment and Training program includes
unemployment insurance, but excludes 20 percent of all earned income.
It is evident in some instances that exclusions are driven by the
program's purpose, such as encouraging the participant to seek
employment. While excluding some portion of earned income may
provide an incentive to work, state and local administrators
indicated that these differences not only confuse administrators and
clients, but they can result in situations where economically
disadvantaged workers may not receive needed services because the
different eligibility criteria exclude them from the program that
provides the services they need.
Table III.3
Income Definitions for Programs
Targeting the Economically Disadvantaged
Uses IRS
taxable Excludes $30
income Includes Excludes + one-third
Income including all 20% of of earned
excludes capital earned earned income first
Program UI gains income income 4 months
-------------------- -------- ------------ -------- ---------- ------------
JTPA IIA Training X X
Services for the
Disadvantaged-Adult
JTPA IIA State X X
Education Programs
JTPA IIA Incentive X X
Grants
Job Opportunities X
and Basic Skills
Training
Food Stamp X
Employment and
Training
Family Self- X
Sufficiency Program
Educational X X
Opportunity Centers
Vocational
Education-Basic
State Programs\a
Student Literacy
Corps\b
--------------------------------------------------------------------------------
\a Excluded from analysis due to wide latitude that states can
exercise in determining income.
\b Program requirements do not include a technical definition of
income.
Differences in income definitions are further magnified by income
exclusions that can vary from state to state. These rules produce a
range of state income eligibility limits. For example, in the Foster
Grandparent Program and Senior Companion Program, income levels
cannot exceed 125 percent of the poverty guidelines or 100 percent of
the poverty guidelines plus any Supplemental Security Income (SSI)
provided by the state. As a result, a senior in one state receiving
an SSI state supplement may be eligible for the program with income
that exceeds 125 percent of the poverty level, while a senior in
another state that does not provide SSI would be excluded if income
exceeds 125 percent of the poverty level.
Some programs allow automatic eligibility to participants enrolled in
another program. This tends to soften the effect of some of the
above differences. However, minor differences exist within
cross-eligibility definitions that can also create coordination
barriers. For example, a person receiving food stamps is
automatically eligible for the JTPA program. However, some people
may choose not to participate in the Food Stamp program. It has been
reported that only 59 percent of persons eligible for food stamps
actually received them in 1989.\1 A report by the National Commission
for Employment Policy\2 concluded that since many Hispanic families
are clustered around JTPA's income cut-off point and choose not to
participate in the Food Stamp program, many economically
disadvantaged Hispanics are ineligible for needed JTPA training
services. To resolve this problem, this report recommended that
"receipt of Food Stamps," as an eligibility requirement, should be
removed from the law and replaced with "eligible for Food Stamps."
--------------------
\1 Time for a Change, Welfare Simplification and Coordination
Advisory Committee Report (June 1993).
\2 Training Hispanics: Implications for the JTPA System, National
Commission for Employment Policy Report (Jan. 1990).
AGE REQUIREMENTS IN OLDER WORKER
PROGRAMS
========================================================== Appendix IV
The four programs that target older workers vary in their minimum age
requirements. As shown in table IV.1, two programs had a minimum age
requirement of 55, although one program gave priority to those aged
60. The other two programs had a minimum age requirement of 60.
These relatively minor age differences may result in some older
workers under 60 years of age being excluded from needed program
services.
Table IV.1
Older Worker Programs Differ in Age
Requirements
Program name Age 55 Age 60
---------------------------------------- -------- --------
JTPA Older Worker X
Senior Community Service Employment X\a
Foster Grandparent X
Senior Companion X
------------------------------------------------------------
\a Priority is given to applicants 60 years of age.
Although the revised JTPA program amendments and the Older Americans
Act, which authorizes the Senior Community Service Employment Program
(SCSEP), call for increased coordination, these programs are prime
examples of the difficulties that can arise when programs provide
complementary services, but their eligibility requirements are not
compatible. The SCSEP may be used to help older people, such as
displaced homemakers,\1 gain work experience while JTPA finances
skills training. Both the JTPA and the SCSEP define an "older
worker" as one 55 years of age or older. However, SCSEP may exclude
some older workers because it gives service priority to those
applicants 60 years of age and older.
Even those seniors who meet the age criteria may sometimes be
excluded because of additional differences in requirements related to
economic status. Under JTPA, clients' incomes must be no more than
100 percent of the poverty guidelines or 70 percent of the lower
living standard income level, but SCSEP allows participants to have
incomes that are up to 125 percent of the poverty guidelines.
Although JTPA does allow administrators to waive the income
guidelines for 10 percent of participants, these workers must also
face serious barriers to employment. According to a local program
administrator, where these programs are located within the same
building, clients are frequently referred from SCSEP to JTPA, but do
not qualify under the latter program's more stringent income
criteria. In these instances, not only is it difficult for case
managers to track client eligibility, but clients themselves feel
confused and discriminated against.
In addition, program eligibility may vary from state to state. SCSEP
includes Social Security as part of countable income, but for the
JTPA Older Worker Program, each state has the choice of including or
excluding Social Security income.
--------------------
\1 An individual who was a full-time homemaker for a substantial
number of years and derived the substantial share of his or her
support from a spouse and no longer receives such support.
LOWER AND UPPER AGE LIMITS FOR
YOUTH PROGRAMS
=========================================================== Appendix V
Programs targeting youth vary in eligibility requirements because of
differences in their lower and upper age limits. As shown in figure
V.1, lower age limits ranged from 11 to 16 years of age, while upper
age limits ranged from 19 to 27.
Figure V.1: Lower and Upper
Age Limits Differ Among Youth
Programs
(See figure in printed
edition.)
These differences in age criteria may result in youth being denied
access to some programs. For example, as shown in table V.1, the
JTPA Disadvantaged Summer Youth Program and the Federal Employment
for Disadvantaged Youth both create summer employment for
disadvantaged youth. Although both allow youth up to 21 years of age
to participate, the programs had different requirements regarding
lower age limits. Under the Federal Employment for Disadvantaged
Youth, administered by the Office of Personnel Management (OPM),
youth under the age of 16 are excluded from the program. However,
the JTPA summer program, administered by the Department of Labor,
permits youth to enroll in the program at 14 years of age.
Table V.1
Lower and Upper Age Limits for Youth
Programs
11 - 13 - 14 - 16 - 16 - 16 -
Program 27 19 21 20 21 24
-------------------------------- ------ ------ ------ ------ ------ ------
JTPA IIC Disadvantaged Youth X
JTPA IIC Disadvantaged Youth- X
Incentive Grants
JTPA IIC Disadvantaged Youth- X
State Education Programs
JTPA IIB Summer Youth Employment X
and Training Program (Regular)
JTPA IIB Summer Youth Employment X
and Training Program (Native
American)
JTPA Job Corps X
Youth Fair Chance X
Transitional Living for Runaway X
and Homeless Youth
Independent Living X
School Dropout Demonstration
Assistance\a
Vocational Education-Community X
Based Organizations
Upward Bound X
Talent Search X
School to Work\b
Federal Employment for X
Disadvantaged Youth-Summer
Youthbuild X
--------------------------------------------------------------------------------
\a Program requirements include a minimum age of 16, but no upper age
limit.
\b Program is proposed in fiscal year 1994 budget.
DEFINITIONS OF JOB LOSS AMONG
DISLOCATED WORKER PROGRAMS
========================================================== Appendix VI
Nine separate dislocated worker\1 programs have been established to
ensure that workers adversely affected by special circumstances, such
as increased imports or defense downsizing, have access to
reemployment assistance. Although all programs commonly target those
workers who are dislocated, as shown in table VI.1, programs vary in
their definitions of what constitutes "job loss." These differences
may result in workers being denied access to program services.
Table VI.1
Definitions of Job Loss Among Dislocated
Worker Programs
Reduced
Notice of Date of hours and Voluntary
layoff hire/layoff wages separation
Program accepted restricted accepted accepted
------------------------ ------------ ------------ ------------ ------------
JTPA-EDWAA-Dislocated X
Workers (Local SDA
Allotment)
JTPA-EDWAA-Dislocated X
Workers (Governor's 50%
Discretionary)
JTPA-EDWAA-Dislocated X
Workers (Secretary's 20%
Discretionary)
JTPA Defense Conversion X
Adjustment Program
JTPA Clean Air X
Employment Transition
Assistance
JTPA Defense X X X
Diversification
Trade Adjustment X X
Assistance-Workers
Vocational Education-
Demonstration Centers
for the Retraining of
Dislocated Workers\a
Transition Assistance X X
Program
--------------------------------------------------------------------------------
\a This program does not have a specific definition for dislocated
workers.
Although most dislocated worker programs accepted a layoff or
termination notice as proof of job loss and eligibility for services,
three programs restricted access depending on hire and separation
dates. The complexity of such requirements is evidenced by one
program that targets four subgroups of workers adversely affected by
military base closings. The JTPA Defense Diversification Program
excludes members of the Armed Forces if they were hired or were not
on active duty on or before September 30, 1990; other targeted groups
are excluded if they received layoff notices or were terminated
before October 1, 1992, or after September 30, 1997. Members of the
Armed Forces and Defense employees are excluded for eligibility until
they are within 180 days of the separation; civilian employees
working at military installations are excluded from eligibility until
they are within 24 months of separation. A second and similar
program, the Transition Assistance Program, also restricts access
unless the member of the Armed Forces is within 180 days of
separation. Until these arbitrary time periods have expired, some
workers may be denied access to services needed to provide the
necessary training and skills in order to make the transition to new
industries and occupations.
A third program, Trade Adjustment Assistance (TAA), focuses on
trade-impacted workers and has complex job loss requirements related
to the date of separation as well as the level of employment activity
during that time. For example, the worker's first qualifying
separation must occur after the "impact date" (the date on which
layoffs began or threatened to begin), within 2 years of the worker's
being certified as adversely affected by imports, and before the
termination date of the certification. Further, the worker must have
(1) been employed at least 26 of the 52 weeks preceding the last
layoff in this trade-affected employment and (2) received wages of
$30 or more per week. In our prior report that compared TAA with the
Economic Dislocation and Worker Adjustment Assistance (EDWAA)
program, state officials said that such complex regulations
contribute to the lack of coordination between the two programs. An
important indicator of this lack of coordination is that only 10
percent of all TAA participants received EDWAA services during fiscal
year 1990.\2
--------------------
\1 Workers with an established work history who have lost their jobs
as a result of structural changes in the economy and who are not
likely to find new jobs in their former industries or occupations.
\2 Dislocated Workers: Comparison of Assistance Programs
(GAO/HRD-92-153BR, Sept. 1992).
PROGRAM ANNUAL OPERATING CYCLES
========================================================= Appendix VII
Coordination of services is also hampered by differences in program
operating cycles within each of the four target groups. According to
one administrator, these barriers result in "program coordination
becoming...an art," particularly in view of additional state and
local operating time frames superimposed on the differing program
operating cycles. For these reasons, state officials contacted were
in agreement that a standard operating year would greatly facilitate
program coordination.
As shown in table VII.1, the 38 programs we reviewed operated on four
different annual cycles. Some programs completed their planning
process and began operation on January 1, while others did not
complete planning and begin operation until October 1. Most programs
(20) operated on the basis of a program year (July 1-June 30); 12
programs operated on the federal fiscal year (October 1-September
30); 4 programs operated on an academic year (September 1-August 31);
and 2 programs operated on a calendar year (January 1-December 31).
These operating cycles varied within each target group regardless of
administering agency. For example, two programs previously discussed
that target dislocated workers are both administered by the
Department of Labor (see appendix VI). However, the TAA program
operates on a fiscal-year basis while the EDWAA program operates on a
program-year basis.
Administrators attempting to coordinate programs through joint
planning have difficulty when operating cycles do not match. One
administrator told us that his state operates on a
September-to-August time frame, while the JOBS program operates on
the federal fiscal year (October 1 to September 30) and JTPA operates
on a program year (July 1 to June 30). Although administrators
strive to coordinate the programs through joint planning, it is
difficult, without parallel operating cycles, to match up available
funding with estimates of clients that may need assistance. To
accomplish joint planning, the state must resort to several
circuitous strategies. Among other things, some agencies involved
"lowball," that is, only commit resources they know will be
available, and contribute additional resources, as available, at a
later time. Other agencies make commitments contingent on expected
funding so they are not held to prior commitments when their funding
"falls through."
Another state administrator commented that although coordination is
hampered by many service delivery barriers, such as conflicting
eligibility requirements, other barriers, such as differing operating
cycles, pertain to the process or "mechanics" of administering
programs. Accordingly, in his view, establishing a standard
operating year would be "the key to start the car"-- the impetus
needed to begin collaborative planning leading to successful
coordination.
Table VII.1
Programs Within Four Target Groups
Differ in Definition of Annual Operating
Cycle
Jan. 1- July 1- Sept. 1- Oct. 1-
Target group/program Dec. 31 June 30 Aug. 31 Sept. 30
-------------------------------- ---------- ---------- ---------- ----------
Older Workers
Senior Community Service X
Employment Program
JTPA IIA Training Programs for X
Older Individuals
Foster Grandparent Program X
Senior Companion Program X
Dislocated Workers
--------------------------------------------------------------------------------
JTPA EDWAA-Dislocated Workers X
(Local SDA Allotment)
JTPA EDWAA-Dislocated Workers X
(Governor's 50% Discretionary)
JTPA EDWAA-Dislocated Workers X
(Secretary's 20% Discretionary)
JTPA Defense Conversion X
Adjustment
JTPA Clean Air Employment X
Transition Assistance
JTPA Defense Diversification X
Trade Adjustment Assistance- X
Workers
Vocational Education- X
Demonstration Centers for the
Retraining of Dislocated Workers
Transition Assistance Program X
Disadvantaged
--------------------------------------------------------------------------------
JTPA IIA Training Services for X
the Disadvantaged-Adult
JTPA IIA State Education X
Programs
JTPA IIA Incentive Grants X
Job Opportunities and Basic X
Skills Training
Food Stamp Employment and X
Training
Family Self-Sufficiency Program X
Vocational Education-Basic State X
Programs
Educational Opportunity Centers X
Student Literacy Corps X
Youth
--------------------------------------------------------------------------------
JTPA IIC Disadvantaged Youth X
JTPA IIC Disadvantaged Youth- X
Incentive Grants
JTPA IIC Disadvantaged Youth- X
State Education Programs
JTPA IIB Training Services for X
the Disadvantaged-Summer Youth
Employment and Training Program
(Regular)
JTPA IIB Summer Youth Employment X
and Training Program (Native
American)
JTPA Job Corps X
Youth Fair Chance X
Transitional Living for Runaway X
and Homeless Youth
Independent Living X
School Dropout Demonstration X
Assistance
Vocational Education-Community X
Based Organizations
Upward Bound X
Talent Search X
School to Work X
Federal Employment for X
Disadvantaged Youth-Summer
Youthbuild X
--------------------------------------------------------------------------------
MAJOR CONTRIBUTORS TO THIS REPORT
======================================================== Appendix VIII
HEALTH, EDUCATION, AND HUMAN
SERVICES DIVISION,
WASHINGTON, D.C.
Clarence Crawford, Associate Director
DETROIT REGIONAL OFFICE
Robert T. Rogers, Assistant Director, Education and Employment,
(313) 256-8011
Edna Saltzman, Evaluator-in-Charge
Jonathon Banas, Intern
Barbara Moroski-Browne, Senior Evaluator
David Porter, Evaluator
Lynda Racey, Evaluator