1. Managing Average Project Duration and Individual Participant Duration SCSEP Business Meeting November 18, 2010 – 2:00 p.m. Presented by: Bennett Pudlin, The Charter Oak Group, LLC Rocco Claroni, Pennsylvania Department of Aging

2. Two Separate Durational Limits 27 month average project durational limit for a grantee (Section 502 (b)(1)(c)) 48 month lifetime durational limit for each participant (Section 518 (a)(3)) The two durational limits are separate: Extensions granted to individual participants count toward average project duration and do not relieve grantee of requirement to maintain 27 month average 2

3. Project Durational Limits 3

4. Grantees are responsible for managing their project so as not to exceed an average project duration of 27 MONTHS 4

5. Project Durational Limits Grantees may request an extension for the coming program year to 36 months, due to exceptional circumstances No extensions beyond 36 months, but grantees may seek the extension each year 5

6. Project Durational Limits All participants enrolled in the last 9 quarters are counted – both exited and still enrolled Time in project is counted from July 1, 2007 – the earliest any grantee could have been affected was October 1, 2009 Approved breaks in participation, properly entered into SPARQ, are excluded from calculations 6

7. Project Durational Limits New durational counter in QPR, field B13, reports the average project duration at all levels for current quarter and last 9 quarters: – Grantee – Sub-grantee – National grantees in a state Official measurement of average project duration applies only at the grantee level 7

8. Project Durational Waiver Requests for waiver of 27 month average project durational limit must be submitted by a grantee to the Department of Labor 8

9. Project Durational Waiver Request Process Waiver request must be based on one of the 5 factors listed in the OAA (Title V Sec. 513 (a)(2)(D)) : High rate of unemployment or poverty Significant downturns in the area served by the grantee or in the national economy Significant number or proportions of participants with barriers to employment Changes in federal, state, or local minimum wage Limited economies of scale 9

10. Project Durational Waiver Request Process Each year, a grantee may request a waiver for the coming program year as part of its grant application If granted, the limit for the next program year will be 36 months 10

11. Project Durational Waiver Request Process The waiver request must include: Statement of the grantee’s current average duration, and an estimate of its average duration for the coming program year Grantee’s efforts to achieve the 27 month average duration 11

12. Project Durational Waiver Request Process The waiver request must include (cont.): Factors constituting extenuating circumstances that warrant an extension to 36 months – If grantee relies on data other than that provided in the goal negotiation process (e.g., sub-state data based on where the majority of its slots are located), it must provide it with the request National grantees must specify whether they are seeking a waiver for the entire grant or certain states only 12

13. Project Durational Waiver Request Process DOL may ask for additional data in evaluating the request An extension, if granted, will be valid for the following program year – Extension will apply to the entire grant for state grantees – For national grantees, extension will apply to specified states or to the entire grant, if warranted 13

14. Project Durational Waiver Request Process Under extraordinary circumstances, a grantee may request an extension for the current program year By definition, goal adjustment factor 2 constitutes extraordinary circumstances for a mid-year extension request 14

15. Project Durational Limit Tools Field B13 of the QPR displays average project duration for the current quarter and the last 9 quarters Includes everyone enrolled on the day the QPR is run and everyone exited during the report period L9Q is the official measure 15

16. Project Durational Limit Tools Good news about the L4Q measure – Smoothes out the trend by taking a long view – Current conditions, e.g., increased duration due to recession, have less impact Not so good news – Hard to manage except at high level, e.g., lower individual participant duration generally means lower average project duration – Currently impossible to calculate direct effect of waivers or other actions on average project duration Tracking current quarter and L4Q over time will show you the direction you are headed 16

17. Project Durational Limit Tools Caution: Rejects will render durational count inaccurate Management Reports can provide details – Current/Exited report provides durational information about all current and exited participants along with other basic information about these participants – Participants with Approved Breaks shows everyone who has a break properly entered into SPARQ and thus is excluded from the count while on break 17

18. Project Durational Limit Tools Management Reports – Waiver of Durational Limit (WDL) report and new waiver report to be developed this spring will identify everyone approaching 48 months and everyone granted an extension – New DQR function shows rejects affecting duration counts in Management Reports 18

19. Participant Durational Limits 19

20. Participant Durational Limits Individual participants are only eligible to receive SCSEP services for a lifetime total of 48 months unless an extension is granted For participants, the count began on July 1, 2007 – Participation prior to July 1, 2007 does not count toward the durational limit 20

21. Participant Durational Limits Limit applies to any and all enrollments in SCSEP – Whether or not consecutive – With any grantee or sub-grantee – With any SCSEP funding source The first date a participant can reach the 48- month durational limit is June 30, 2011 21

22. Participant Durational Limits Grantees may request a waiver for participants who reach the 48-month limit and meet at least one of the following factors:  Severe disability  Frail  Old enough for but not receiving Social Security Title II  Low literacy skills  Severely limited employment prospects in areas of persistent unemployment  Limited English proficiency  75 or older 22

23. Participant Durational Limits Waiver factor must be in existence and updated in SPARQ during the program year in which the waiver is requested Or in the last quarter of the previous program year if waiver is requested in the first quarter of a program year If a grantee makes an extension request and participant meets at least one waiver factor, an individual durational limit extension will be granted for 12 months Grantees may request multiple 12-month extensions 23

24. Participant Durational Limits Grantees should have a durational limit policy that adopts one of these options: 48 months with waivers – All participants eligible for an extension if they have any one of the 7 waiver factors; or – Participants eligible if they meet certain specified waiver factors; or – Participants eligible if they meet one or more wavier factors AND additional criteria specified by the grantee 48 months with no waivers – all participants exit SCSEP at 48 months Durational limit of less than 48 months, as approved by DOL 24

25. Participant Durational Limits If grantee chooses 48 months with waivers, its waiver policy should specify what criteria grantee will use in deciding who is entitled to a waiver 25

26. Waiver Process Waiver request process will be automated in SPARQ: Grantee will use waiver utility (coming this spring) to identify a participant for which it seeks a waiver Utility will determine if a waiver factor has been updated in the appropriate time period 26

27. Waiver Process Waiver request process (cont.): If waiver factor has been updated, DOL will approve the request Participant’s record in SPARQ will indicate date of new durational limit WDL report lists all participants approaching durational limit and new report will list all participants who have received waivers 27

28. Waiver Factors SCSEP contains 7 data elements (P51-P57) that determine whether a participant qualifies for a waiver of the 48 month lifetime durational limit for participation in SCSEP Waiver factors are also counted in the Most in Need measure 28

29. Waiver Factors The 7 waiver factors are: Severe disability Frail 75+ years of age Low literacy skills Old enough for but not receiving Title II Social Security assistance Severely limited employment prospects in areas with persistent unemployment Limited English proficiency 29

30. Waiver Factors The 7 waiver factors can be entered at enrollment or whenever they first occur Factors must be updated, as applicable Grantees may only receive credit in the Most in Need measures for a waiver factor in the program year in which it was first entered, or in which it was updated 30

31. Waiver Factors Example 1: A participant is identified as severely disabled at time of enrollment on 7/10/10 31

32. Waiver Factors On 4/15/11, a new table of persistent unemployment is published and the participant now lives in an area of persistent unemployment. Example 2: At enrollment on 12/29/10, a participant has severely limited employment prospects but does not live in an area of persistent unemployment under the current table for persistent unemployment. 32

33. Waiver Factors Priorities of service vs. waiver factors Both count as Most in Need Serve different purposes and have different procedures 33

34. Waiver Factors Priorities of service identify whether grantees are enrolling individuals for whom Congress wants special consideration in enrollment 8 factors entered only at time of enrollment (no updates ever) Credit given in Most in Need measure every year participant is enrolled 34

35. Waiver Factors Priorities of service are: Veterans and eligible spouses Disability Limited English proficiency Low literacy skills Reside in a rural area Have low employment prospects Have failed to find unemployment after utilizing services under WIA Title I Homeless or at risk of homelessness 35

36. Waiver Factors Waiver factors determine extension entitlement when participant reaches 48 month limit (and in last quarter of prior program year if limit is reached during first quarter of program year) Waiver cannot occur before June 30, 2011 36

37. Waiver Factors Participant becomes disabled 3 months later. Participant becomes severely disabled 3 years later. Example 3: A participant is not disabled at time of enrollment. 37

38. Waiver Factors Note: Limited English proficiency and low literacy skills are both priorities of service and waiver factors They only count once in Most in Need measure If recorded at enrollment as priorities of service, credit is given each year To be used as a waiver factor at 48 months, however, they must be updated in the year of the waiver request. 38

39. Waiver Factors Using waiver factors for extension of 48 month individual participant duration: Participant must have one or more waiver factors in existence during the program year of the request – Or within the previous 3 months, if the request is made within the first 3 months of a program year 39

40. Waiver Factors Using waiver factors for extension of 48 month individual participant duration (cont.): Determination is based on the existence of the factor at the time of the request No participant is subject to the individual 48 month limit until June 30, 2011 40

41. Waiver Factors More on waiver factors: Approved breaks in participation properly entered into SPARQ do not count toward either durational limit Grantees need to have durational limit policies, including whether waivers will be granted, and policies on approved breaks in participation 41

42. Waiver Factors Waiver factor updates: “Yes” answers to waiver factors should only be updated in SPARQ once each year No need to update “yes” to “no” – failure to update means there will be no credit in the new year Whatever you do, don’t update “yes” to “no” before the final program year QPR is frozen, or you will lose credit to which you are entitled 42

43. Waiver Factors Waiver factor updates: For fields coded “no,” you may attempt to update as often as you wish Check at least once before 6/30 of each year 43

44. Waiver Factors Blackout periods Currently, no waiver factor can be updated during Q1 Persistent unemployment (P54) has an additional blackout period from 1/1 – approx. 4/15 each year when new data become available New release of SPARQ in early spring of 2011 will eliminate the Q1 blackout period. The persistent unemployment blackout is permanent 44

45. Waiver Factors Participants have two chances every program year to qualify for persistent unemployment From 7/1 – 12/31 under the old list From 1/1 – 6/30 under the new list* *Update based on new list cannot be entered until blackout period ends 45

46. Participant Durational Limit Tools Management Reports – Current/Exited shows several different individual participant durations and grantee averages – Waiver of Durational Limit (WDL) shows everyone within 4 quarters of durational limit and when each waiver factor was last updated – Most in Need/Waiver Action Report shows all participants who have any waiver factors and when they were last updated – Participants with Approved Breaks shows all participants with an approved break entered into SPARQ and thus not included in the durational counts during their breaks 46

47. Participant Durational Limit Tools Management Reports – New report on extensions granted will be released in early spring SPARQ will have new utility for requesting extensions, and participant screen will be updated with date of each participant’s new durational limit Caution: 25 rejects affect the durational counts. DQR has new function that shows you just these rejects – WDL report tells you if a participant has had other enrollments that can affect your count 47