418 Program Management Requirements

Georgia State Seal

Georgia Division of Aging Services
Home and Community-Based Services Manual

Chapter:

400

Effective Date:

Section Title:

Program Management Requirements

Reviewed or Updated in:

MT 2014-13

Section Number:

418

Previous Update:

418.1 Program Accountability and Performance Measures

For each Grantee, the Secretary of Labor is authorized to establish performance measures designed to promote continuous improvement in performance. Performance measures are indicators of performance and levels of performance applicable to each indicator. The U.S. Department of Labor has established a Performance Accountability System which holds each Grantee (National Sponsors and States) accountable for attaining quality levels of performance with respect to core performance measures.

Performance Measures Defined (20 C.F.R. § 641.700)

  1. Indicators of performance. There are currently eight performance measures, of which six are core indicators and two are additional indicators. Core indicators (defined in § 641.710) are subject to goal-setting and corrective action (described in § 641.720); that is, performance level goals for each core indicator must be agreed upon between the Department and each grantee before the start of each program year, and if a grantee fails to meet the performance level goals for the core indicators, that grantee is subject to corrective action. Additional indicators (defined in § 641.710) are not subject to goal-setting and are, therefore, also not subject to corrective action.

  2. Core Indicators. Section 42 U.S.C. § 3056k(b)(1) establishes the following core indicators of performance:

    1. Hours (in the aggregate) of community service employment

    2. Entry into unsubsidized employment

    3. Retention in unsubsidized employment for six months

    4. Earnings

    5. The number of eligible individuals served

    6. The number of most-in-need individuals served (the number of participating individuals described in § 518(a)(3)(B)(ii) or (b)(2) of the OAA).

  3. Additional indicators. Section 42 U.S.C. § 3056k(b)(2) establishes the following additional indicators of performance:

    1. Retention in unsubsidized employment for one year

    2. Satisfaction of the participants, employers, and their host agencies with their experiences and the services provided

    3. Any other indicators of performance that the Secretary determines to be appropriate to evaluate services and performance

  4. Affected entities. The core indicators of performance and additional indicators of performance are applicable to each grantee without regard to whether the grantee operates the program directly or through subcontracts, sub-grants, or agreements with other entities. Grantees must assure that their sub-grantees and lower tier sub-grantees are collecting and reporting program data.

  5. Required evaluation and reporting. An agreement to be evaluated on the core indicators of performance and to report information on the additional indicators of performance is a requirement for application for, and is a condition of, all SCSEP grants.

Core Indicators Defined (20 C.F.R. § 641.710)

  1. The core indicators are defined as follows:

    1. “Hours of community service employment” is defined as the total number of hours of community service provided by SCSEP participants divided by the number of hours of community service funded by the grant minus the number of paid training hours in the period. Paid training hours are excluded from this measure.

    2. “Entry into unsubsidized employment” is defined as follows: Of those who are not employed at the date of participation, the number of participants employed in the first quarter after the exit quarter divided by the number of participants who exit during the quarter.

    3. “Retention in unsubsidized employment for six months” is defined as follows: Of those who are employed in the first quarter after the exit quarter, the number employed in both the second and third quarters after the exit quarter divided by the number of participants who exit during the quarter.

    4. “Earnings” is defined as follows: Of those participants who are employed in the first, second and third quarters after the exit quarter, total earnings in the second and third quarters after the exit quarter, divided by the total number of exiters during the quarter.

    5. “The number of eligible individuals served” is defined as the total number of participants served divided by a grantee’s authorized number of positions, after adjusting for differences in minimum wage among the States and areas.

    6. “Most-in-need”, or the number of participating individuals described in § 518(a)(3)(B)(ii) or (b)(2), is defined by counting the total number of the following characteristics for all participants and dividing by the number of participants served. Participants are characterized as most-in-need if they:

      • Have a severe disability

      • Are frail

      • Are age 75 or older

      • Meet the eligibility requirements related to age for, but do not receive, benefits under title II of the Social Security Act (42 U.S.C. § 401 et seq.)

      • Live in an area with persistent unemployment and are individuals with severely limited employment prospects

      • Have limited English proficiency

      • Have low literacy skills

      • Have a disability

      • Reside in a rural area

      • Are veterans

      • Have low employment prospects

      • Have failed to find employment after utilizing services provided under title I of the Workforce Investment Act of 1998 (29 U.S.C. § 2801 et seq.); or

      • Are homeless or at risk for homelessness.

  2. The additional indicators are defined as follows:

    1. “Retention in unsubsidized employment for 1 year” is defined by the formula: Of those who are employed in the first quarter after the exit quarter: The number of participants who are employed in the fourth quarter after the exit quarter divided by the number of participants who exit during the quarter.

    2. “Satisfaction of the participants, employers, and their host agencies with their experiences and the services provided” is defined as the results of customer satisfaction surveys administered to each of these three customer groups. The Department will prescribe the content of the surveys.

Levels of Performance Defined (20 C.F.R. § 641.720)

  1. Initial agreement. Before the beginning of each Program Year, the Department and each grantee will undertake to agree upon expected levels of performance for each core indicator, except as provided in paragraph (b) of 20 C.F.R. § 641.730.

    1. As a first step in this process, the Department proposes a performance level for each core indicator, taking into account any statutory performance requirements, the need to promote continuous improvement in the program overall and in each grantee, the grantee’s past performance, and the statutory adjustment factors articulated in paragraph (b) of this section.

    2. A grantee may request a revision to the Department’s initial performance level goal determination. The request must be based on data that supports the revision request. The data supplied by the grantee at this stage may concern the statutory adjustment factors articulated in paragraph (b) of this section, but is not limited to those factors; it is permissible for a grantee to supply data.

Adjustments to Levels of Performance

Levels of performance may be adjusted only due to:

  • High rates of unemployment, poverty, or receipt of TANF benefits in the areas served;

  • Significant downturns in the local or national economy;

  • A significant number of Grantee’s enrollees having one or more barriers to employment relative to the enrollees of other Grantees;

  • Changes in Federal, State, or local minimum wage requirements;

  • Limited economies of scale for the provision of community service employment and other authorized activities in the areas served by the grantee.

Each program year, the Department of Labor will determine if Grantees have met the established level of performance. It also will evaluate national Grantees on their performance both nationally and in every State in which they operate.

418.2 DAS Performance Requirements for Sub-Grantees

In additional to compliance with all SCSEP DOL accountability requirements, DAS SCSEP sub-grantees also will be responsible for:

  • Supervision of program execution

  • Selection of a sub-grantee SCSEP Project Director

  • Selection of a Sub-project (Note: The sub-grantee also may serve as a Host Agency (see below)), providing participant training directly and foregoing the appointment of a sub- project.

  • Achieving DOL-mandated Core Performance Measure annual goals

  • Monitoring Core Performance Measures on a regular basis through the SPARQ database (SCSEP Performance and Results Quarterly Report Database)

  • Ensuring the following record-keeping guidelines are followed:

    • Keeping a permanent record for each participant in the SCSEP program.

    • Each participant record is kept current and remains confidential at all times.

    • Participant files and confidential records are maintained in a secure location at the sub-grantee or sub-project’s office.

    • All records are kept in participant files with the exception of the I-9 and any medical information. This information is maintained in a separate file, accessible only by authorized personnel.

    • Each participant has the right to review any and all documents constituting his or her personnel record.

    • All records must be retained for a minimum of six years after termination of the contract and until resolution of any pending litigation, claim, or audit involving those records.

  • Selection of appropriate Host Agencies. A Host Agency must be a nonprofit, nonpartisan organization. Those eligible to serve as Host Agencies are public agencies and private organizations exempt from taxation under the provisions of Section 501(c)(3) of the Internal Revenue Code of 1954. Political parties cannot act as Host Agencies.

  • Obtain a signed Host Agency Agreement (see www.odis.dhr.state.ga.us/5000_agi/Aging%20Directives%20Index.htm MAN 5300, Section 400, Chapter 412).

  • Ensure that Host Agencies comply with all guidelines provided in the DAS SCSEP Host Agency Handbook (see www.odis.dhr.state.ga.us/5000_agi/Aging%20Directives%20Index.htm MAN5300, Section 400, Chapter 404).

  • Compliance with DOL “Maintenance of Effort” requirements, as outlined in 20 C.F.R. § 641.844—Note: Maintenance of Effort refers to the assurance that community service assignments for participants will:

    1. result in an increase in employment opportunities in addition to those which otherwise would be available;

    2. not result in the displacement of currently employed workers, including partial displacement of currently employed workers, including such partial displacement as reduction in hours of non-overtime work, wages or employment benefits;

    3. not impair any existing contract for service, or result in the substitution of federal funds provided for the operation of the host agency for other funds in connection with work that otherwise would be performed;

    4. not substitute any community service assignment funded by the project sponsor for any existing federally assisted job; and not be in a position that is the same as or substantially the same as one that is occupied by any other person who is on layoff.

  • Regular monitoring of the activities of the sub-projects using the DAS SCSEP Monitoring Tool (www.odis.dhr.state.ga.us/5000_agi/Aging%20Directives%20Index.htm MAN 5300 Section 400, Chapter 406).

  • Regular monitoring of Host Agencies using the DAS Host Agency Monitoring Tool (www.odis.dhr.state.ga.us/5000_agi/Aging%20Directives%20Index.htm MAN 5300 Section 400, Chapter 410).

418.3 Monitoring

The U.S. Department of Labor (DOL) requires that the State periodically monitor the performance of grant-supported activities to assure that project goals related to the recruitment of priority populations are being achieved and that all requirements of the Older Americans Act and its rules and regulations are being met. The DOL-approved DAS SCSEP monitoring tool can be found at: www.odis.dhr.state.ga.us/5000_agi/Aging%20Directives%20Index.htm MAN 5300, Section 400, Chapter 406.

Performance by all sub-grantee will be measured monthly by DAS, on a cumulative basis, against the goals and standards specified in the SCSEP regulations:

  • The performance standards for program activities under the sub-grant contract with DAS will be monitored closely by the DAS SCSEP Coordinator through desk reviews of reports, quarterly narrative reports, and annual on-site monitoring visits.

  • DAS will review and analyze monthly financial reports in the Aging Information Management System (AIMS) to determine the sub-grantees’ compliance with Department of Labor and DAS spending goals. The sub-grantees will be expected to perform according to monthly financial plans, as stipulated in the DAS contract. Appropriate procedures must be initiated to assure that the total sub-grant is not over- or under-expended.

  • All sub-grantee expenditures must comply with DOL limitations of expenditure of SCSEP funds and matching requirements as outlined in 20 C.F.R. § 641.867, § 641.873, and § 641.809. DAS SCSEP Allowable Costs and the related statutory regulations are outlined in the chart below.

  • The match requirement for SCSEP funds must follow the guidelines outlined in the SCSEP Final Rule, sections 20 C.F.R. § 641.809 (d) and 20 C.F.R. § 641.873 (b). Match will be tracked in three separate categories, in compliance with the DAS Allowable Costs document of 11.14.2012 (copy attached in Appendix): Administrative, Enrollee Wages/Benefits, and Other Costs.

All three categories can be matched with in-kind.

418.4 SCSEP Sub-Grantee Proposal Process

Agencies who wish to apply to DAS to administer the SCSEP program must respond to a Request for Proposal (RFP). DAS will disseminate application deadlines and other details when a RFP opportunity becomes available:

The Request for Proposal is available at: www.odis.dhr.state.ga.us/5000_agi/Aging%20Directives%20Index.htm MAN 5300, Section 400 Chapter 408.

All of the following sections of the RFP must be completed by the applicant and submitted according to the submission guidelines:

  • General Contract Terms

  • Scope of Services

  • Application Face Sheet

  • Completed Narrative Responses

  • Program Budget

  • Letters of Support

  • Conflict of Interest Statement

  • Minority Business Policy

  • Reciprocal Preference Law

The successful sub-grantee will contract with DAS to administer the SCSEP program in designated areas. Each sub-grantee contract will contain the same DOL Assurances agreed to by DAS (listed below). Sub-grantees will be held accountable to abide by all DOL Assurances. In addition, sub-grantees are responsible for assuring any sub-projects they contract with also abide by the Assurances.

418.5 DOL SCSEP Assurances

DOL SCSEP Programmatic Assurances

The DOL Employment Training Administration (ETA) has determined that the programmatic assurances below reflect standard grant requirements and are consistent with sound program practices.

Grantees must certify that they will conform to these assurances throughout the period of the grant by checking each of the assurances below. These assurances apply at all levels regardless of the grantee administrative structure. These assurances apply fully to any sub-recipient, local project or grantee staff involved in the delivery of services. See Attachment A, Programmatic Assurances.

418.6 Four-Year State Plan Process

DOL requires state grantees to submit a 4-year state plan, which includes proposed activities for both state sub-grantees and national grantees. DOL provides detailed instructions for the state plan preparation and 2-year update process in TEGLs. The TEGL for the most recent state plan process can be viewed at:

wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5563