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References. JTPA Regulations, 20 CFR Parts 632; DINAP Bulletin 92-17. Background. A great deal of high-level attention, including Congressional and Administration interest, was focused on the 1993 summer program SUMMER CHALLENGE I. In addition to the attempt to significantly boost funding, attention and effort was also devoted to enhancing the two major components of the program: Work experience and education. Although some solid progress was made, it is clear that additional efforts to enrich the program must be made. Findings from last year's program show that the work experience component was a success. Youth were engaged in real work, not make-work; they wanted to work and demonstrated this desire,, they were generally well-supervise; and they acquired work discipline skills. The amount and quality of educational services provided varied. A variety of activities were conducted under the rubric of "academic enrichment" e.g., personal counseling, pre-employment counseling, and vocational exploration. These activities are worthwhile, but they tend to inflate the amount of time and resources expended to improving basic educational skills and other academic pursuits. The President, the Secretary of Labor and the Secretary of Education continue to place a high priority on enriching academic services to maintain and improve educational skills for all summer youth enrollees, including Native American youth. Educational skills attainment remains the basic tenet of the academic enrichment component of the JTPA SYP. While improvements in reading, math and other educational competencies are the primary emphases, this does not preclude the provision of other services and activities which have a direct correlation with not only improving educational performance, but also develops skills and strategies necessary to function at home, school and the workplace. Goals for the CY 1994 SYP. The primary thrust of the CY 1994 program will be an integration of work and learning. Full implementation of the integration of work and learning will not be achieved in one summer, but implementation should begin with this year's program. In addition to the purposes of the Summer Youth Employment and Training program set forth in the statute, DINAP has established the following goals for this summer's program: a. Work and Learning Integration. Provide classroom-based education in which the youth learn the real work world applications of the academic disciplines they are studying. Provide at least limited educational services to the majority of participants nationally; such services may be delivered in a classroom or in a workplace context, or both. b. Meaningful Work. Ensure that youth receive the benefit of meaningful work experience which: -- (1) demonstrates the value of the work to be performed to the individual, the employers, and his/her community, -- (2) assists the youth to acquire basic work competencies and discipline--e.g., punctuality and regularity with regard to attendance, taking direction; cooperating with peers, productivity. -- (3) offers a workplace context in which work and learning are integrated,, the Secretary's Commission on Achieving Necessary Skills (SCANS) foundations and competencies--or a reasonable variation thereof -- should be used in identifying what is to be learned in the workplace. c. Counteract Erosion. Ensures that enrollees are provided academic enrichment which, at a minimum, counteracts the erosion of basic educational skills associated with school vacations and strive to increase the /eve/ of educational skills, particularly in reading, writing, and mathematics (academic enrichment). d. Linkages. Develop linkages with the Title IIA programs and other available programs to preserve and enhance educational and work maturity gains achieved by the Title II-B program. e. Private Sector. Enlists the cooperation of the private sector to: -- (1) increase the number of unsubsidized job opportunities available to disadvantaged youth; -- (2) expose youth to work in a private sector setting; and -- (3) Provide income for work to economically disadvantaged youth to benefit them, their families, and their communities. f. Future Programs. Use this summer's experience as a means to further enhance and enrich subsequent summer jobs programs in such areas as: -- (1) innovative educational components; and -- (2) the relationship between success in the world of work and educational attainment. Maximum Utilization of Funds. Grantees will expend the total amount of funds available to the maximum extent feasible and correspondingly, the maximum number of youth will be served. Total funds available include carry-in funds from 1993 and the 1994 base allocation. Objective Assessment/Individual Services Strategy. As a result of the 1992 amendments to the JTPA, section 401 Indian and Native American grantees must assess each participant of the SYETP to determine his/her educational and supportive services needs and employment interests and aptitudes. Based on this assessment, program operators shall devise an Individual Service Strategy (ISS) which addresses the participant's needs and the delivery of such services, including educational services. No specific format for objective assessment/ISS will be supplied. Since section 401 Indian and Native American grantees are experienced in preparing employment development plans (EDPs), this new requirement should be accommodated relatively easily. It is suggested that a streamlined EDP should meet this need. If an ISS has been prepared under the 401 program or another JTPA program, the need to modify it for the SYP should be minor, if at all. Technical Assistance and Training. Grantees will receive assistance provided by DINAP Federal Representatives via the telephone for the most part due to limited resources; however, in some instances on-site visits will be made. In addition, the Employment and Training Administration is contracting with Brandeis University in conjunction with KRA to conduct three training workshops around the country in March. They will focus on an enriched program, particularly the integration of work and learning. Section 401 Indian and Native American grantees will be invited to participate along with local service delivery area (SDA) grantees. Section 401 grantees will also be provided with the following: a. copies of the plans of several past successful summer programs (under separate cover). NOTE: It is hoped that these program models will be helpful to grantees in planning and administering summer programs, as well as stimulating new ideas and directions for their programs; and b. peer Section 401 SYP TA providers who will give hands-on, on-site assistance to grantees who require it. Several grantees who have run successful summer programs may be asked to visit grantees who request special TA. This form of TA will necessarily be reserved for grantees who experience major problems. Program Oversight and Monitoring. Effective oversight of program operations is an essential element in meeting the SYP goals and objectives. Your Federal Representative will be in touch with you to confirm specifics on oversight plans. These visits are intended to ensure that major issues are addressed before they become problems. The TA provided during these visits should help grantees keep their programs on track. Reporting and Data Collection. It is clear that the press/media, the general public and the Administration will want information on the progress of grantees in achieving the SYP goals, especially enrollment and expenditure data. While special reporting requirements will not be imposed this year, section 401 Indian and Native American grantees are requested to maintain ongoing information on planned total enrollment and planned total obligations for the entire summer program, broken out by overall total and academic enrichment in the event special requests for information become necessary. The only formal report that will be required is the end-of-program report which is due on November 15, 1994. Program Guidance for Section 401 Indian and Native American Grantees Who Do Not Receive Title 11-B Funds. Many section 401 Indian and Native American grantees who do not receive Title 11-B funds operate similar summer programs for young people in urban and other non-reservation areas. Please be advised that States and SDAs undertake separate initiatives for the summer youth, mostly in the form of technical assistance. Additional Guidance. a. Personal Development. This activity which is commonly referred to as "Life Skills", nurtures attitudinal and behavior changes necessary to succeed in the classroom and in the world of work. It is a legitimate activity and many program operators and educators consider this a vital ingredient to success of the SYP. These activities can and should take place in both the classroom and on-the-job. b. Continuity of Services. Linkages with Title II programs throughout the year are encouraged, where appropriate. In the past, national efforts have been undertaken with Indian Housing, Office of Indian Education (BIA), and Indian Education Technical Assistance Center (IETAC) to encourage linkages. Section 401 Indian and Native American grantees are encouraged to work locally with any entity that could assist in making the SYETP successful. c. Increased Coordination Information Exchange with Local School Systems. Contacts with schools fade rapidly once summer operations begin and they are rare after the conclusion of the program. To the extent possible, section 401 Indian and Native American grantees are encouraged to maintain ongoing relationships. d. Private Sector Initiatives. Limited private sector internships entry employment experience was authorized for the summer program by reference in the JTPA amendments, but it was not defined. Wages can be paid to youth who are working in private establishments. In cases where this program design is used, grantees must guard against perceptions and occurrences of favoritism in selecting employers. In selecting private sector employers, limited internships should be done on the basis of value-added, i.e., what contribution they make to the youth's development such as introducing them to skill training, mentoring and vocational exploration. Inquiries. Questions should be directed to your DINAP Federal Representative.

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References. a. JTPA Regulations at 20 CFR Part 632. b. DINAP Bulletin 85-15, Administrative Cost Limit. c. OMB Circulars A-87 and A-122. d. DINAP Bulletin 86-10, Linkages and Program Coordination. e. DINAP Bulletin 87-27, Technical Assistance Guide on Linkages and Program Coordination f. DINAP Bulletin 88-20, Administrative Requirements for DOL Grantees. g. DINAP Bulletin 91-22, Instructions and Reporting Requirements. h. DINAP Bulletin 92-26, Transition Guidance for the Implementation of the Job Training Partnership Act (JTPA) Amendments of 1992. Background. The PY 1994 Title 401 appropriation is $64.2 million. This amount is $2.3 million more than the current funding level of 61.9 million. Proposed revised regulations have been drafted in cooperation with the Native American Employment and Training Council's Regulations Work Group. The Council's representatives provided excellent input and as a result the final product represents an improvement over the present regulations. We will try to clear and issue these regulations in time for implementation of the PY 1994 program. However, at the present time, it appears that this will be problematical given current administrative requirements. Unless revised regulations are issued, Section 401 Indian and Native American grantees will continue to use the existing regulations at 20 CFR Part 632. Therefore, the mandatory provisions in the 1992 amendments to the Job Training Partnership Act which were covered in DINAP Bulletin 92-26 must be followed if we continue to operate under the existing regulations. Information. a. General. A new Comprehensive Annual Plan (CAP) must be submitted to obtain funding for PY 1994, which is the last year under the current four year Master Plan agreement (see attachment 2). Where applicable, a new Summer Plan (SP) for the summer of 1994 must also be submitted (see attachment 2). To assist you in this process the standard list of assurances, certifications, and special conditions are part of this package (see attachment 3). They must be submitted with your grant proposal. A Master Plan is not required to be submitted. b. Special Instructions. All references to 41 CFR Part 29.70 will be superseded by Departmental regulations at 29 CFR Part 95 which will implement the revised A-1 10 requirements. The Department will issue 29 CFR Part 95 by May 1994 and will forward these requirements to all grantees when they are published. The documents referenced in section 2 of this bulletin, are to be used as appropriate in the preparation of the PY 1994 CAP and CY 1994 SP. Follow the Budget Information Summary (BIS) and Program Planning Summary (PPS) instructions in DINAP Bulletin 91-22. Follow the reporting instructions in DINAP Bulletin 91-22. New forms, which have been approved by the Office of Management and Budget, contain minor modifications to existing forms (see attachment 4). Please discontinue use of all previous versions of these forms. c. Common Errors to Avoid. Over the years, certain kinds of errors in the CAP and SP have appeared in many grantee plans. It is recommended that grantees use the attached checklist (see attachment 5) to ensure that these errors are eliminated. This will enable DINAP staff to facilitate the processing of CAPs and SPs and thereby prevent delays in funding. d. Carry-in Policy. The carry-in policy is as follows: -- (1) 20 percent of total available Title IV-A funds can be carried in from PY 1993 to PY 1994. -- (2) The normal 20 percent of total available Title II-B funds which can be carried in from the calendar year 1993 Summer Title II-B program to the calendar year 1994 Summer Title 11-B program is waived in order to permit maximum spending of funds for this year's program. However, the 20 percent carry-in level will be imposed for the calendar year 1995 Summer Title 11-B program since the unique problems that occurred over the last two years are not expected to recur. -- (3) The vast majority of grantees have managed their Section 401 grants in a manner that has kept their carry-in at 15 percent or less of the total available Section 401 funds. Grantees are reminded that there are thousands of Native Americans who need help immediately and to carry in funds is to neglect the immediate needs of these people. Every effort should be made to keep carry-in down to an absolute minimum amount. -- (4) Under the current regulations, total available funds for any funding period are defined as new money allocated for that funding period plus allowable carry-in from the prior funding period. This is the figure reflected on line 11 of the BIS from which the 20 percent carry-in limit is calculated. e. Performance Management Goals for PY 1994. The effects of performance standards on program design, service delivery and participants served have drawn increased public attention within the JTPA system, and particularly within the grantee community. For this reason, current performance measures were reviewed for their contribution to advancing current Departmental policy as part of a lengthy process of consultation with the Native American Employment and Training Council and the Performance Standards Technical Work Group. Program objectives developed jointly with the Native American Employment and Training Council support Departmental goals set for the JTPA and, in addition, include goals relevant to the JTPA Section 401 program (see attachment 6). As a result of this consultative process, performance standard revisions were proposed to support the following ETA and JTPA Section 401 program goals: -- (1) Targeting services to a more at-risk population. -- (2) Improving the quality and intensity of services that lead to long-term employability and increased earnings. -- (3) Placing greater emphasis on basic skills acquisition to qualify for employment or advanced education and training. -- (4) Promoting comprehensive coordinated human resource programs to address the multiple needs of at-risk populations. -- (5) Advancing the economic and social development of Indian and Native American communities in ways that promote each community's goals and lifestyles. -- (6) Designing and implementing a system that is objective, equitable and understandable to the Indian and Native American JTPA grantee and one which provides a standard of accountability for program performance. Allocations. This is the first year that the 1990 Census will be used for allocation purposes. To eliminate the possibility of any major program disruptions, a hold harmless factor has been applied for both the Title 401 program. (90 percent) and the Summer Youth Program (85 percent). As a result of using these factors, no grantee will reduced more than 6.6 percent for the Title 401 IV-A grant or 12.3 percent for the Title II-B grant. It is recognized that by applying a hold harmless percentage, the impact of the 1990 Census data will have to be faced in subsequent years. However, there is a need for a shake out period where problems and issues can be identified and sufficient time is permitted to adjust local service arrangements. Therefore, a hold harmless will be employed for an additional two years. The 1990 Census data were employed consistent with past practices; therefore, there should be no major impact that can be readily identified. There are some problems where adjustments were made to the 1980 Census data that are not in accordance with the governing formula. Since the Census data do not support such adjustments, they have not been incorporated into the allocations contained in attachment 1. Contact will be made with those grantees on an individual basis to address specific problem areas that have been identified thus far. Also, the concerns by the Oklahoma grantees have not been addressed. It is recognized that we must jointly deal with these concerns. When the additional Census data on Oklahoma are obtained, a meeting will be arranged with all the grantees in Oklahoma to determine next steps in overcoming any misunderstandings that may exist. If you identify any problems or have any concerns on the allocations, please contact your Federal Representative to discuss them. A notice will be published in the Federal Register with the allocations for this program which will ask for comments. You do not have to wait for this notice to raise any questions you may have. Closeout. The Department will close out the award when it determines that all applicable administrative actions and all required work of the grant has been completed. Within 90 days after the expiration or termination of the grant, the grantee must submit all final financial, performance and other reports required as a condition of the grant. The Department will make every effort to provide the grantee with all required closeout forms prior to the expiration or termination of the grant. Upon request by the grantee, the Department may extend the 90 day time frame to submit the closeout documents. Action. Grantees must forward their SYP by April 15, and their CAP by April 29, 1994 to DINAP. Inquiries. Questions should be directed to your Federal Representative (202) 219-5504.

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References. DINAP Bulletins 93-14 and 93-15 Background. A series of questions have been raised on the original bulletin. While the questions have been responded to individually, the answers may be helpful to everyone (see attachment 1). Along with the questions and answers, grantees will find three replacement pages - Revised Signature Page (formerly Attachment 7) to be used to transmit the grants; Special Clause No. 1 - Indirect Cost, page 2; and Part III Special Conditions, page 1, item 9. In addition, a series of changes have been made to the initial allocations to correct problems that have been identified with the data. Reservations in six States were included in the totals which have been deleted (see attachment 2 for new allocations). Other corrections for misassignments of geographical areas that have been agreed upon with staff from the U.S. Bureau of the Census. Native Americans Allotments Methodology. Since several individuals indicated a need for a description of how the allotments were prepared, the following information on the methodology is included below: a. 1994 11-B Summer Youth Program. Total 11-B funds available for Native Americans for the Summer Youth Program are allotted among grantees on the basis of the number of reservation youth ages 14-21 for each grantee as compared to the total number of reservation youth ages 14-21 for all grantees, subject to an 85% hold harmless adjustment. The 85% hold-harmless adjustment provides that no grantee with such reservation youth for the year for which the allotment is being determined will receive less than 85% of its allotment percentage (percentage of total lI-B funds allotted) for the previous year. (NOTE: this is not 85% of the dollar amount for the previous year.) If the grantee's current year allotment percentage is less than that, the grantee is assigned an amount equal to 85% of its allotment percentage for the previous year, applied to the current year total 11-B funds available for allotment to Native Americans. Funds necessary to cover grantees held harmless are subtracted from total funds available, with the remaining funds distributed to remaining grantees on the basis of their relative share of remaining reservation youth, as described above. The number of reservation youth ages 14-21 are provided by the Census Bureau from the 1990 Census data (see attachment 3). b. 1994 IV-A Program. Total IV-A funds available for Native Americans are allotted among grantees as follows: -- (1) 75% of the funds are allotted on the basis of the number of persons in poverty for each grantee as compared to the total number of persons in poverty for all grantees -- (2) 25% of the funds are allotted on the basis of the number of unemployed persons for each grantee as compared to the total number of unemployed persons for all grantees. The amounts so calculated for grantees are subject to a 90% hold-harmless adjustment. The 90% hold-harmless adjustment provides that no grantee will receive less than 90% of its allotment percentage (percentage of total IV-A funds allotted) for the previous year. (NOTE: this is not 90% of the dollar amount for the previous year.) If the current year allotment percentage is less than that, the grantee is assigned an amount equal to 90% of its allotment percentage for the previous year, applied to the current year total IV-A funds available for allotment to Native Americans. Funds necessary to cover grantees held harmless are subtracted from total funds available, with the remaining funds distributed to remaining grantees on the basis of their relative share of remaining poverty and unemployment, as described in the formula above. Poverty and unemployment data are provided by the Census Bureau from the, 1990 Census data (see attachment 3). Inquiries. Questions should be directed to your Federal representatives on (202) 219-5504.

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