DIRECTIVE	:	TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 07-97
TO	:	ALL STATE JTPA LIAISONS ALL STATE EMPLOYMENT SECURITY AGENCIES ALL STATE WORKER ADJUSTMENT LIAISONS ALL ONE-STOP CAREER CENTER SYSTEM LEADS
FROM	:	DAVID HENSON Director Office of Regional Management
SUBJECT	:	Year 2000 Compliance for the Job Training Partnership Act System

1. Purpose. To emphasize the importance of States addressing Year 2000 issues affecting the Job Training Partnership Act (JTPA) system, provide guidance on Year 2000 compliance, and seek the assistance of States in identifying and overcoming potential problems.

2. Background. At 12:01 on New Year's morning of the year 2000, many computer systems that use two digits to track dates will recognize "double zero" as the year 1900 rather than the year 2000. This will pose serious problems for Program Year 1999 JTPA reporting.

   The Employment and Training Administration (ETA) has addressed this issue in a series of communications over the past two years, primarily focused on the State Employment Security Agencies (SESAs). In addition, ETA Regional Office staff have worked with. the employment and training system to provide Year 2000 information to SESA Administrators;" Job Training Partnership Act (JTPA) Liaisons, Worker Adjustment Liaisons and One-Stop contacts to ensure awareness of the Year 2000 problems and begin assessing the States' SESAs and non-SESA systems.

   Initial informal information gathering for the JTPA system in the fall of 1996, resulted in 26 SESAs indicating that eight had compliant systems, four had plans to replace their systems, three were counting on third party vendors to upgrade their software, and 11 SESAs would be converting their own software.

   In the summer of 1997, an informal status assessment of 39 States responding, found:

   • 24 States were aware of the year 2000 issues;

   • 10 States had assessed their systems;

   • 5 States completed renovation;

   • 2 States had implemented needed changes; and

   • 2 States had validated and tested their systems.

   There is a considerable variety in the way JTPA data are collected at State and local levels. The State JTPA reporting system consists of 53 State agencies, approximately 640 SDAs/SSGs, and additional subrecipients which use varying hardware and software systems. Some are centralized, while others operate in a decentralized small system environment. Participant JTPA data is gathered at the local level, forwarded to States and then provided to the Department of Labor via contractor. Financial reports are submitted to the Regional Offices. Due to the nature of the JTPA reporting systems, there is no easy "fix" which will apply to each of the local level JTPA system.

   The informal assessments suggest that ETA needs to refine the assessment process, better define the problems, and follow-up to assure States are pursuing actions that will lead to computer systems compliant with the year 2000.

   There are a series of web sites which provide further background on the year 2000 issues, including:

   1. General Accounting Office Report, Year 2000 Computing Crisis: An Assessment Guide, access on internet (http://www.gao.gov.), February 1997, describes a "Year 2000 Conversion Model to decrease the risks;

   2. Information Technology Support Center's (ITSC) Web site (http:'//333.itsc.State.md.us/) provides references for Year 2000 reporting issues; and

   3. Chief Information Officer (CIO),Council Committee on Year 2000 (www.itpolicy.gsa.gov/mks/yr2000/ y2khome.htm) addresses Year 2000 goals and processes.

3. State Responsibilities. Solutions to the Year 2000 problems require leadership and management commitment. JTPA Liaisons need to make the Year 2000 compliance a priority, and see to it that sufficient resources in terms of staff and funding are made available.

   States are responsible for meeting the standards for financial management and participant data systems as defined in 20 CFR 627.425 and ensuring that their subrecipients also meet these standards. The JTPA financial system of the States, SDAs/SSGs, and their subrecipients must provide fiscal controls and procedures that are adequate to meet the "Generally Accepted Accounting Principles," prepare accurate reports, and track expenditures and participant activities in an accurate manner.

   To meet these responsibilities, the State JTPA agencies have a variety of actions they may pursue:

   • Work with SDAs/SSGs and State Year 2000 teams to assure proper assessment, planning, conversion, and testing for mission critical systems;

   • Work with the SESA staff responsibly for automated data processing when appropriate, since the SESAs influence JTPA reporting in 40 States;

   • Identify needs and request JTPA statutory and regulatory waivers for obtaining administrative assistance and relief, e.g., pro-0ride relief from caps on allowable amounts for administration; and

   • Promote the SDA use of the five percent incentive funds under 202(c)(1)(b) for the costs of developing Year 2000compliant information, including funds set-aside for technical assistance and capacity building.,

4. Federal Responsibilities. ETA is responsible for reviewing theadequacy of the reporting systems as provided for in the JTPA statute and regulations, and for providing Year 2000 status reports to the Secretary of Labor. The ETA Regional Offices will:

   • Serve as the primary interface with 'the States on facilitating Year 2000 compliance issues; and

   • Collect and verify information related to the Year 2000 reports, sharing relevant information among their respective States through meetings.

   The ETA National Office, working with its contractor, the Information Technology Support Center (ITSC), which has the requisite experience with the SESAs and technical expertise with Year 2000 issues to support the project, will:

   • Add a JTPA section to the ITSC Web Page site, which will provide an electronic reference section for State, local program, and subrecipients;

   • Conduct and refine previous assessments of the JTPA system with regard to Year 2000 compliance;

   • Prepare a summary report with a recommendations on how State JTPA systems can achieve Year 2000 compliance;

   • Provide technical assistance materials and information, such as lessons learned and arrange for consultations via the ITSC;

   • Plan and conduct with Regional Staff, regional/multi-regional meetings for brokering solutions among SDAs/subrecipients.

   In carrying out these responsibilities, ETA will seek support from the public interest groups, such as the National Governors' Association, the National Association of Counties, the National Conference of Mayors, as well as the National Association of Private Industry Councils. These groups will be able to promote Year 2000 awareness, make referrals to resource centers within and across State boundaries, and share information with their constituents.

5. Action Required. JTPA Liaisons are requested to: a. work with your SDAs\SSGs, grantees and their subrecipients to ensure compliance; b. notify the appropriate ETA Regional Office of your point of contact for Year 2000 issues; and c. inform your Regional Office of any problems and ideas for assisting others.

6. Inquiries. For further information contact your Regional office.