PROGRAM MEMOS (PM) Why do we have PM’s? How Many? Each PM, it’s purpose and summary

WHY DO WE HAVE PM’S?  PM’s create a unified structure to the federal requirements.  Are required either in the Older Americans Act (OAA) or by the U.S. Department of Labor (DOL).

HOW MANY PM’S ARE THERE? There are four CDA PM’s for SCSEP. CDA does not prescribe how each individual Area Agency on Aging (AAA) should run their program as each AAA and community is different.

WHAT ARE THE CDA PM’S?  PM Durational Limits and Transition Planning  PM Grievance and Termination Policy Changes  PM Participant Termination Policy  PM Authorized Break in Participation Policy

PM DURATIONAL LIMITS AND TRANSITION PLANNING  Increases job skills by encouraging rotation in host agency assignments.  Encourages practices to assist participants in finding unsubsidized employment.  Motivates participants to focus on the end goal of unsubsidized employment.  Provides step to be taken during the final year on the program for participants.

Grievance  Each AAA has a grievance procedure that adheres to 22 CCR §  Must follow AAA grievance procedures  CDA and DOL will only receive a grievance to ensure that the grievance policy was followed – no determination is made  DOL will only determine Civil Rights grievances, if elevated to its level Termination  PM provides a more in-depth, step-by-step process PM GRIEVANCE AND TERMINATION POLICY CHANGES

PM GRIEVANCE AND TERMINATION POLICY CHANGES (CONTINUED) General Grievance Procedure  First Level of Resolution  AAA coordinator receives complaint, investigates, and makes determination  AAA Informal Administrative Review  AAA Director receives complaint, investigates, and makes determination  Final Grievance Resolution  Complainant can request an impartial hearing before a officer/panel

PM PARTICIPANT TERMINATION POLICY Required under Code of Federal Regulation (CFR), Title 20, Part (d) – 20 CFR (d)  Participant voluntary separation  Participant involuntary separation  Prohibitions  Notification requirements  Voluntary Separation Procedures  Involuntary Termination Procedures

PM PARTICIPANT TERMINATION POLICY (CONTINUED) Participant Voluntary Separation  Unsubsidized Employment  Relocation outside of the Planning and Service Area  Retirement  Health Reason  Institutionalization  Family reasons  Incapacitation or death

PM PARTICIPANT TERMINATION POLICY (CONTINUED) Participant Involuntary Separation caused by  Participant,  Project, and  For Cause Prohibitions  Project may not terminate participants solely on the basis of their age. No upper age limit allowed.

Notification Requirements  Must provide a written copy of the termination and grievance policies  Must verbally review termination policy and grievance procedures during enrollment/orientation  Tip – Have the participant sign a copy for your files  Must give a 30-day notice prior to involuntary termination  Include detail on the reason(s) for termination  Grievance policy should be included  Participants voluntarily separating should sign and date the Exit Form  If not possible to get a signature, a case note is acceptable  Tip - include in the Exit Form comment box in SPARQ) PM PARTICIPANT TERMINATION POLICY (CONTINUED)

 Code of Federal Regulation (CFR), Tile 20, Part (d) – 20 CFR (d)  Permits a participant to request a formal leave of absence from SCSEP  Stops the Durational Limit (DL) clock, only for the break period  Two types of leave  Voluntary Leave  Administrative Leave  Authorized Breaks are unpaid  Must be approved or declined in advance by the local SCSEP Coordinator PM AUTHORIZED BREAK IN PARTICIPATION POLICY

Voluntary Leave  Up to 60 days  Illness, Injuries, Estate Settlement, Marriage, Family Care, Bereavement, Hospitalization Administrative Leave  Workers’ Compensation  Administrative Review  Host agency closure  Administrative Investigation PM AUTHORIZED BREAK IN PARTICIPATION POLICY (CONTINUED)

Enter all start and end dates for Authorized Breaks into SPARQ  Include case notes in the comment box Extensions can be granted  Maximum of 90 days  Letter requesting extension must be submitted to the SCSEP State Director  PM outlines what requirements should be included PM AUTHORIZED BREAK IN PARTICIPATION POLICY (CONTINUED)

Where to find PM’s? CDA website Request a copy from your SCSEP Specialist NOTE: Your agency’s action on PM’s are reviewed during monitoring