[Federal Register Volume 59, Number 23 (Thursday, February 3, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-2387]
[[Page Unknown]]
[Federal Register: February 3, 1994]
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Part V
Department of Education
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Department of Labor
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Cooperative Demonstration--School-to-Work Opportunities State
Implementation Grants Program; Notices
DEPARTMENT OF EDUCATION
DEPARTMENT OF LABOR
Cooperative Demonstration--School-to-Work Opportunities State
Implementation Grants Program
AGENCIES: Department of Education and Department of Labor.
ACTION: Notice of final priority, selection criteria, and other
requirements for Fiscal Year 1994.
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SUMMARY: The Secretaries of Education and Labor announce an absolute
priority for awards to be made in fiscal year 1994 to enable States to
implement plans for statewide School-to-Work Opportunities systems.
These systems would offer young Americans access to programs designed
to prepare them for a first job in high-skill, high-wage careers, and
to increase their opportunities for further education. The Secretaries
also announce selection criteria that will be applied in evaluating
applications submitted for this competition.
EFFECTIVE DATE: The provisions in this notice take effect either 45
days after publication in the Federal Register or later if the Congress
takes certain adjournments. If you want to know the effective date of
these provisions, call or write the Department of Education contact
person.
FOR FURTHER INFORMATION CONTACT: Marian Banfield, U.S. Department of
Education. Telephone: (202) 205-8838. Or Janet Moore, U.S. Department
of Labor. Telephone (202) 219-5281. Individuals who use a
telecommunications device for the deaf (TDD) may call the Federal
Information Relay Service (FIRS) at 1-800-877-8339 between 8 a.m. and 8
p.m., Eastern time, Monday through Friday.
SUPPLEMENTARY INFORMATION:
Background
The Departments of Education and Labor have entered into a
partnership to establish a national framework within which all States
can create statewide School-to-Work Opportunities systems. These
systems will help our youth acquire the knowledge, skills, abilities,
and labor market information they need to make a smooth and effective
transition from school to career-oriented work or to further education
or training.
Currently, three-fourths of America's high school students enter
the workforce without baccalaureate degrees. Many of them do not
possess the basic academic and entry-level occupational skills
necessary to succeed in the changing workplace. Unemployment among
American youth is intolerably high, and earnings of high school
graduates have been falling relative to those with more education. In
addition, the American workplace is changing in response to heightened
international competition and new technologies, and these forces, which
are ultimately beneficial to the Nation, are shrinking the demand for
and undermining the earning power of unskilled labor. The School-to-
Work Opportunities initiative is the result of a broad-based and
growing interest in creating school-to-work transition systems in which
young Americans choose and navigate paths to productive and
progressively more rewarding roles in the workplace.
Under the School-to-Work Opportunities initiative and the fiscal
year 1994 Cooperative Demonstration Program competition, Federal funds
will be used as ``venture capital'' to stimulate State and local
creativity in establishing statewide School-to-Work Opportunities
systems. To achieve this systemic reform, States may choose to build on
and enrich current promising programs such as tech-prep education,
career academies, school-to-apprenticeship, cooperative education,
youth apprenticeship, and business-education compacts, that can be
developed into programs under a School-to-Work Opportunities system.
Through the formation of partnerships among secondary and postsecondary
educational institutions, private and public employers, labor
organizations, government, community groups, parents, and other key
groups, communities will take ownership and responsibility for giving
American youth access to skills and employment opportunities that will
launch them on paths leading to high-skill, high-wage careers.
Together, States and localities will take the lead in determining goals
and priorities, developing new strategies, and measuring progress.
The Federal role in the School-to-Work Opportunities initiative is
important, but limited to the establishment of broad national criteria
and a framework within which States create School-to-Work Opportunities
systems. The Federal role is to (a) invest in State and local
initiatives by providing seed capital; (b) help States and localities
learn from each other and from the experience of our international
competitors; (c) build a knowledge base of effective school-to-work
models, including strategies that meet the needs of disadvantaged youth
and that can be implemented successfully in poor communities; and (d)
create a national framework through common core criteria and national
standards.
School-to-Work Opportunities Systems
The School-to-Work Opportunities initiative provides for a
substantial degree of State flexibility and experimentation, but all
State systems will share the following common features and basic
program components.
The basis of a School-to-Work Opportunities system is (1) the
integration of work-based and school-based learning that provides
students, to the extent practicable, with broad instruction on all
aspects of the industry students are preparing to enter, (2) the
integration of occupational and academic learning, and (3) the linking
of secondary and postsecondary education.
To build bridges from school-to-work, programs must provide
students with an integrated array of learning experiences in the
classroom and at the worksite. In order to ensure that students receive
these learning experiences, all School-to-Work Opportunities programs
must incorporate three basic program components: Work-based learning,
school-based learning, and connecting activities. These three core
components include--
Work-based learning that includes providing students with
a planned program of job training and experiences relevant to a
student's career and leading to the award of a skill certificate, paid
work experience, workplace mentoring, and instruction in general
workplace competencies.
School-based learning that includes career awareness and
career exploration and counseling, initial selection of a career major
by interested students not later than the beginning of the 11th grade,
a coherent multi-year sequence of instruction typically beginning no
later than the eleventh grade and ending typically after at least one
year of postsecondary education tied to high academic and skill
standards, which would be developed under the proposed ``Goals 2000:
Educate America Act,'' and regularly scheduled evaluations to identify
students' academic strengths and weaknesses, academic progress,
workplace knowledge, and goals; and
Connecting activities to ensure coordination between the
work-based and school-based learning components of each School-to-Work
Opportunities program, which includes matching students with employers'
work-based learning opportunities, serving as a liaison among employer,
school, teacher, parent, and student participants, providing technical
assistance to employers and others in designing work-based learning
components, providing assistance to students who have completed the
program in finding appropriate employment, continuing their education,
or obtaining additional training, collecting information regarding the
outcome of students' participation in the School-to-Work Opportunities
program, and linking youth development activities under the School-to-
Work Opportunities program with employers' strategies for upgrading the
skills of their workers.
School-to-Work Opportunities programs will result in students
attaining: (1) A high school diploma or its equivalent, (2) a
certificate or diploma recognizing successful completion of one or two
years of postsecondary education, if appropriate, and (3) a skill
certificate. In addition, these students will be ready to begin a first
job on a career track and pursue further education and training.
Grant Program Schedule
The School-to-Work Opportunities initiative is proceeding on two
funding tracks--(1) during fiscal year 1994, the initiative is being
funded under current legislative authority in the Job Training
Partnership Act and the Carl D. Perkins Vocational and Applied
Technology Education Act (Perkins Act); and (2) for fiscal years 1995
through 2002, the Departments plan to fund the initiative under the
proposed ``School-to-Work Opportunities Act of 1993,'' which was
introduced in Congress on August 5, 1993 as H.R. 2884 and S.1361. The
funds will be made available through a grants program. The Department
of Education and the Department of Labor are jointly designing and
providing for the administration of a State grants program, that
consists of--
(a) Development Grants, that are currently being awarded to each
State for developing a statewide School-to-Work Opportunities plan; and
(b) Implementation Grants, as described in this notice, awarded
competitively to States that can demonstrate substantial ability to
begin full-scale operations and implement the statewide plan.
The Secretaries have reserved approximately $250,000 in fiscal year
1994 funds appropriated under the Job Training Partnership Act, to
assist the Territories in developing and implementing School-to-Work
Opportunities systems. Specific information regarding the availability
of these funds will be announced at a later date.
The efforts that take place under both current authority and the
proposed legislation are built on a phased-in approach that allows
States to ``come on line'' at different points in time, depending on
each State's readiness to undertake broad-scale change and on the
availability of funds. Development Grants financed from funds requested
by the Department of Labor under the Job Training Partnership Act began
to be awarded to States during December, 1993 and are continuing to be
awarded in January, 1994 to permit States to begin or enhance planning
and developmental efforts to create comprehensive statewide School-to-
Work Opportunities systems.
Each Development Grant discussed above is being awarded for a nine-
month period. The Secretaries may make additional Development Grants
available subsequent to that period to States that do not receive an
Implementation Grant under this competition, if those States
demonstrate substantial progress towards developing a comprehensive
statewide School-to-Work Opportunities plan and if they demonstrate
that Federal funds will be used effectively.
Implementation Grants Competition
By this notice, the Secretaries are reserving a portion of the
funds appropriated under the Perkins Act in fiscal year 1994 for grants
to States to implement statewide School-to-Work Opportunities systems
based on State plans. The Secretaries are also establishing selection
criteria to be applied in evaluating applications for those funds. The
Secretaries are limiting eligibility for implementation grants to
States because the Secretaries have concluded that, for this
competition, the purposes of 34 CFR 426.4(b)(2) can best be achieved by
awarding grants only to State level applicants. Implementation Grants
will be funded for up to a five-year period. The Secretaries anticipate
that continuation awards will be funded under the School-to-Work
Opportunities legislation, once it is enacted. Although there may be
certain differences between requirements under the legislation as
eventually enacted and grant requirements under this notice, the
Secretaries do not expect these to be fundamental.
Grantees under this competition will be required to fund local
partnerships to carry out activities under the School-to-Work
Opportunities program. The Secretaries intend grantees to fund local
partnerships through subgrants, as authorized by the fiscal year 1994
Department of Education Appropriations Act (Pub. L. 103-112).
On October 14, 1993, the Secretaries of the Departments of
Education and Labor published a notice of proposed priority and
proposed selection criteria for this program in the Federal Register
(58 FR 53388).
Note: This notice of final priority does not solicit
applications. A notice inviting applications under this competition
is published in a separate notice in this issue of the Federal
Register.
Analysis of Comments and Changes
In response to the Secretaries' invitation in the notice of
proposed priority, 27 parties submitted comments. An analysis of the
comments and of the changes since publication of the notice of proposed
priority is published as an appendix to this notice.
Changes in the Notice
In responding to comments received and in developing the final
notice, the Secretaries have considered the persuasiveness of the
numerous suggestions made by the various commenters. The Secretaries
have also considered the House and Senate School-to-Work Opportunities
bills currently being considered by Congress. The Secretaries have made
some of the changes suggested by commenters because the Secretaries
concluded that these changes served to further the purposes of the
School-to-Work Opportunities initiative. In addition, in the interest
of facilitating grantees' transition from funding under the Cooperative
Demonstration authority to funding under the anticipated School-to-Work
Opportunities legislation, the Secretaries have also made changes that
are consistent with the Cooperative Demonstration authority in the Carl
D. Perkins Vocational and Applied Technology Education Act, and, where
possible, with the House and Senate bills. Ultimately, although there
may be certain differences between the legislation as enacted and the
notice, the Secretaries do not expect these to be fundamental. To the
extent that any differences exist, the Secretaries plan to provide
grantees with appropriate technical assistance and support in the
transition from funding under the Cooperative Demonstration authority
to systems funding under the anticipated School-to-Work Opportunities
legislation.
An analysis of the comments and of the changes in the notice since
publication of the proposed priority and selection criteria is
published as an appendix to this notice. The following changes made to
the notice are described in the order that they appear in the notice;
technical and other minor changes are not addressed:
(a) Definitions
(1) ``All students''. Reference to ``students who have dropped out
of school'' has been added to the definition of the term ``All
students'' to clarify that drop-out youth are included within the term
and that, therefore, drop-out youth are intended to be served under the
School-to-Work Opportunities program.
(2) ``All aspects of the industry''. The term ``Elements of an
industry'' has been replaced by the term ``All aspects of the
industry'' for the purpose of achieving consistency with the proposed
School-to-Work Opportunities legislation, as well as with the Carl D.
Perkins Vocational and Applied Technology Education Act, both of which
utilize the term ``all aspects of the industry.'' In defining the term,
the Secretaries have chosen to apply the definition contained in 34 CFR
400.4(b) of the regulations implementing the Perkins Act. The use of
the term ``All aspects of the industry'' rather than ``Elements of the
industry'' is not intended to affect a change upon this competition or
upon the requirements contained in the notice.
(3) ``Career major''. Paragraph (d) of the definition of ``Career
major'' has been revised to indicate that a student participating in a
School-to-Work Opportunities program may satisfy the requirement for a
high school diploma by earning the ``equivalent'' of a high school
diploma. The determination of what is the ``equivalent'' of a high
school diploma is left to each State. Paragraph (e) of the definition
of ``Career major'' has been revised by adding the clause ``or
admission into a degree granting college or university.'' This change
is meant to clarify that admission into a degree-granting college or
university is one example of the further education and training to
which a career major may lead.
(4) ``Partnership''. The definition of the term ``Partnership'' has
been revised by adding the words ``non-managerial'' before the word
``employee''. The intent is to clarify what type of employee is being
referred to in the reference to ``labor organizations or employee
representatives.'' The Secretaries consider it likely that managerial
employees will be represented within the category of ``employers.'' In
addition, the definition of ``Partnership'' has been revised to include
within the illustrative list of ``other entities'' that may be included
in a partnership national trade associations working at the local
level; proprietary institutions of higher education, as defined in
section 481(b) of the Higher Education Act of 1965 (20 U.S.C. 1088(b)),
which continue to meet the eligibility and certification requirements
under section 498 of such Act; and vocational student organizations.
(5) ``Skill certificate''. The definition of the term ``Skill
certificate'' has been revised to clarify that the term is intended to
refer to a portable, industry-recognized credential, that certifies
that a student has mastered skills that are benchmarked to high-quality
standards. In addition, under the revised definition, prior to the
development of skill standards under the proposed Goals 2000: Educate
America Act, States are required to develop skill standards under a
process described in their plan. Those standards also must be
benchmarked to high-quality standards.
(6) ``Workplace mentor''. The definition of the term ``Workplace
mentor'' has been revised to clarify that a workplace mentor may be
either an employee at the workplace in which work-based learning is
being provided, or another individual approved by the employer. This
revision makes clear that individuals such as special educators,
vocational rehabilitation counselors, job coaches, and work-study
coordinators, may serve as workplace mentors for all students,
including, in particular, students with disabilities. In addition, the
definition has been revised to require workplace mentors to possess
both the skills and knowledge to be mastered by the student whom they
are mentoring in the workplace.
(b) Absolute Priority
(1) Collaboration with appropriate officials (Paragraph (b)(2)).
The priority has been revised to require collaboration with the State
educational agency rather than the chief State school officer in the
implementation of School-to-Work Opportunities systems. The Secretaries
have made this change in order to be consistent with both the House and
Senate bills. A corresponding change has been made to paragraph (b)(1)
of the selection criterion ``Collaboration and Involvement by Key
Partners.''
(2) Active and continued involvement of interested parties
(paragraph (b)(3)). The priority has been revised to include a
reference to ``related services personnel'' following the reference to
teachers, in the illustrative list of interested parties whose active
and continued involvement in States' School-to-Work Opportunities
systems may be obtained by States. In addition, in the interest of
consistency with the proposed School-to-Work Opportunities legislation
that is expected to govern future funding of State School-to-Work
Opportunities systems and in response to comments, the Secretaries have
added human services agencies, language minority communities, Private
Industry Councils established under the Job Training Partnership Act,
vocational student organizations, and State or regional cooperative
education associations, to the illustrative list of interested parties.
(3) Coordination of the use of funds (paragraph (b)(4)). The
priority has been revised to include the Job Opportunities Basic Skills
Training Program, authorized under part F, title IV, of the Social
Security Act (42 U.S.C. 681 et seq.), programs of the National and
Community Service Act of 1990 (42 U.S.C. 12501 et seq.), and programs
of the Higher Education Act of 1965 (20 U.S.C. 1001 et seq.), among the
related Federal programs with which States are directed to coordinate
their School-to-Work Opportunities systems.
(4) State training strategies (new paragraph (b)(5)). The priority
has been revised to include a new paragraph (b)(5) requiring that
States describe their strategies for providing training for teachers,
employers, mentors, counselors, and other parties in the States'
School-to-Work Opportunities systems. The Secretaries view this change
as being consistent with the intent of the School-to-Work Opportunities
initiative which calls for innovation and fundamental change in States'
secondary school academic and skill training.
(5) Ensuring opportunities for young women to participate
(paragraph (b)(8)). The priority has been revised so that, rather than
being required simply to describe how States will ensure opportunities
for young women to participate in School-to-Work Opportunities
programs, States are required to describe the goals and the methods
that they will use, such as awareness and outreach, to ensure
opportunities for young women to participate in School-to-Work
Opportunities programs in a manner that leads to employment in high-
performance, high-paying jobs in non-traditional employment.
(6) Ensuring opportunities leading to employment (paragraph
(b)(9)). The priority has been revised to clarify that States must
describe how they will ensure opportunities for low-achieving students,
students with disabilities, and drop-outs, to participate in School-to-
Work Opportunities programs in a manner that leads to employment in
high-performance, high-paying jobs. This revision renders paragraph
(b)(9) consistent with paragraph (b)(8), under which States must
describe how they will ensure similar opportunities for young women to
participate.
(7) Service to areas with high concentrations of poor and
disadvantaged youth (paragraph (b)(13)). The priority has been revised
to require States to describe: (1) How their systems will be expanded
over time to cover all geographic areas and (2) how proposed School-to-
Work Opportunities systems will address the needs of students from all
communities, including areas with high concentrations of poor and
disadvantaged youth. (A parallel change has been made to the
``Comprehensive Statewide System'' selection criterion.)
(c) General Program Requirements
(1) Basic Program Components. The ``General Program Requirements''
section, containing the basic components of the School-to-Work
Opportunities program, has been revised to indicate that the high
school diploma requirement may be satisfied when a student is awarded
the ``equivalent'' of a high school diploma, as determined under
standards developed by the State. (Parallel changes have been made to
the definition of the term ``career major'' and to paragraph (e) of the
``Local Programs'' criterion.) In addition, paragraph (a)(1) of the
``General Program Requirements'' section of the priority has been
revised to provide that one of the bases of a School-to-Work
Opportunities system is the integration of work-based learning and
school-based learning ``that provides participating students, to the
extent practicable, with broad instruction in all aspects of the
industry the students are preparing to enter.'' (As previously noted, a
definition of the term ``all aspects of the industry'' has been
provided in the ``Definitions'' section of this notice.)
(2) Work-based Learning. The reference to ``Broad instruction in a
variety of elements of an industry'' has been deleted from the work-
based learning component of the ``General Program Requirements''
section, since reference to broad instruction in all aspects of the
industry that students are preparing to enter is now made in paragraph
(a)(1) of the basic components section of the priority. (See discussion
above in paragraph (c)(1) of this summary).
(3) School-based Learning. The school-based learning component has
been revised to require, among other stated elements, ``career
awareness and career exploration and counseling (beginning at the
earliest possible age)'' in order to help interested students to
identify, select, or reconsider, their interests, goals, and career
majors, ``including those options that may not be traditional for their
gender, race, or ethnicity.'' This change makes clear that promotion of
career awareness and exploration of all career options, at an early
age, is desirable. The determination of the age at which career
awareness, career exploration, and counseling should appropriately
begin, is left to the States. And, the section of the school-based
learning component containing the requirement for regularly scheduled
evaluations has been revised to require those evaluations to identify
students' academic strengths, weaknesses, and ``academic progress,
workplace knowledge, and goals * * *.''
(4) Connecting Activities. The connecting activities component has
been revised to include, among other required elements, ``Providing
assistance to schools and employers to integrate school-based and work-
based learning and integrate academic and occupational learning.'' In
addition, the Secretaries have revised this component to provide an
illustrative list of post program outcome information that grantees may
include among the types of information they collect. The list includes
information on gender, race, ethnicity, socio-economic background,
limited-English proficiency, and disability.
(d) Examples of Statewide Activities. Reference to ``related
services personnel'' has been added to the list of those individuals in
paragraph (c) for whom training could be provided by a grantee under
this priority. In addition, the outreach activities in paragraph (b)
have been revised to include the clause ``stimulating the development
of partnerships in poor communities.'' And, paragraph (h) has been
added to provide that States may work with ``localities to recruit and
retain all students in School-to-Work Opportunities programs, including
those from a broad range of backgrounds and circumstances.''
(e) Allocation of Funds to Local Partnerships. When the notice of
proposed priority was published, the Departments did not have the
authority to require States to award subgrants to local partnerships
with funds awarded under this competition. The 1994 Department of
Education Appropriation Act (Pub. L. 103-112), included a provision
authorizing grantees of funds under this competition to make subgrants
to localities for carrying out School-to-Work Opportunities projects.
In light of this new authority, the notice has been modified so that it
now requires States receiving School-to-Work Opportunities
Implementation grants under this competition to distribute to local
partnerships 65 percent of the amounts they receive, as subgrants to
localities. Under the pending legislation, we expect that this amount
will increase to 75 percent in the second year, and 85 percent in each
year thereafter.
(f) Examples of Activities for Local Partnerships. New paragraphs
(f), (l), (m), and (n) have been added so that included among allowable
activities for local partnerships are: providing career exploration and
awareness services, counseling and mentoring services, college
awareness, and other services to prepare students for the transition
from school to work; designing local strategies to provide adequate
planning time and staff development activities for teachers, school
counselors, and related services personnel; enhancing linkages between
after school, weekend, and summer jobs, and opportunities for career
exploration and school-based learning; and conducting outreach to all
students in a manner that most appropriately meets their needs and the
needs of their communities. Redesignated paragraph (g) has been changed
to specifically include disabled students in graduation assistance
programs.
(g) Safeguards. A reference to labor standards has been added to
paragraph (d) under ``Safeguards,'' to clarify that all existing labor
standards must be applied to School-to-Work Opportunities systems
funded under this competition. Under paragraph (d) as revised, States
are required to provide all students with adequate and safe equipment
and a safe and healthful workplace in conformity with all health,
safety, and labor standards of Federal, State, and local law.
(h) Selection Criteria for Evaluating Applications. In the
discussion of the application review process, the Secretaries have
clarified that, among the factors upon which the Secretaries will base
their funding decisions are the replicability, sustainability, and
innovation of the School-to-Work Opportunities plans described in the
States' applications.
(i) Selection Criteria
(1) Comprehensive Statewide System. In the ``Comprehensive
Statewide System'' criterion, the Secretaries have made a revision to
clarify that each State must propose a feasible plan for expanding the
School-to-Work Opportunities system so that students in all parts of
the State, including communities with high concentrations of poor and
disadvantaged youth, will have the opportunity to participate in the
State's School-to-Work Opportunities program within a reasonable period
of time. This criterion is intended to ensure that State skill
standards and methods of skill assessment are benchmarked to high
quality standards and that students receiving skill certificates under
the School-to-Work Opportunities program will have the opportunity to
enter high-skill, high-wage, employment. Accordingly, the question
``Does the State's process for assessing skills reflect the needs of
high performance workplaces as well as meet the requirements of broad
clusters of related occupations and industries, rather than those of
individual jobs or occupations?'' has been added to this criterion.
(2) Involvement by Key Parties. Under this criterion, States will
be evaluated on whether they propose effective and convincing
strategies for obtaining the active and continued involvement in the
School-to-Work Opportunities program of employers and other interested
parties within the State. The criterion has been revised to reflect the
Secretaries' intent that each State obtain input, from employers and
other key parties, on the State's plans for a proposed School-to-Work
Opportunities system, prior to submitting an application for funds
under this competition.
(3) Resources. The ``Resources'' selection criterion has been
revised to include the question: ``Does the applicant limit
administrative costs in order to maximize the amounts spent on delivery
of services to students enrolled in School-to-Work Opportunities
programs?'' Accordingly, applications will be reviewed to ascertain,
among other things, whether States are planning to limit State and
local partnership administrative costs in order to direct as large a
portion of the funds received as possible toward providing academic and
training services to students participating in their School-to-Work
Opportunities programs.
(4) Student Participation. The ``Student Participation'' selection
criterion has been revised to include ``students with limited-English
proficiency and academically talented students.'' The intent is to be
consistent with the definition of the term ``All students'' (and to
further clarify that School-to-Work Opportunities systems are intended
to meet the needs of academically talented students).
Cooperative Demonstration--School-To-Work Opportunities
Implementation Grants
Definitions
As used in this notice--
``All aspects of an industry'' includes, with respect to a
particular industry that a student is preparing to enter, planning,
management, finances, technical and production skills, underlying
principles of technology, labor and community issues, health and
safety, and environmental issues related to that industry;
``All students'' means students from a broad range of backgrounds
and circumstances, including disadvantaged students, students of
diverse racial, ethnic, and cultural backgrounds, students with
disabilities, students with limited-English proficiency, students who
have dropped out of school, and academically talented students;
``Career major'' means a coherent sequence of courses or field of
study that prepares a student for a first job and that--
(a) Integrates occupational and academic learning, integrates work-
based and school-based learning, and establishes linkages between
secondary and postsecondary education;
(b) Prepares the student for employment in broad occupational
clusters or industry sectors;
(c) Typically includes at least two years of secondary school and
one or two years of postsecondary education;
(d) Results in the award of a high school diploma or its
equivalent, a certificate or diploma recognizing successful completion
of one or two years of postsecondary education (if appropriate), and a
skill certificate; and
(e) May lead to further training, such as entry into a registered
apprenticeship program, or admission into a degree-granting college or
university.
``Partnership'' means a local entity that is responsible for local
School-to-Work Opportunities programs and that consists of employers,
public secondary and postsecondary educational institutions or
agencies, and labor organizations or non-managerial employee
representatives, and may include other entities, such as non-profit or
community-based organizations, rehabilitation agencies and
organizations, registered apprenticeship agencies, local vocational
education entities, local government agencies, parent organizations and
teacher organizations, Private Industry Councils established under the
Job Training Partnership Act, national trade associations working at
the local levels, proprietary institutions of higher education (as
defined in section 481(b) of the Higher Education Act of 1965 (20
U.S.C. 1088(b)), that continue to meet the eligibility and
certification requirements under section 498 of the Higher Education
Act of 1965, vocational student organizations, and Federally recognized
Indian tribes and Alaska Native villages;
``Skill certificate'' means a portable, industry-recognized
credential issued by a School-to-Work Opportunities program under an
approved plan, that certifies that a student has mastered skills that
are benchmarked to high quality standards, such as the skill standards
envisioned in the proposed Goals 2000: Educate America Act, except that
until such skill standards are developed under the Act, the term
``skill certificate'' means a credential certifying that a student has
mastered skills that are benchmarked to high quality standards, issued
under a process described in a State's approved plan;
``Workplace mentor'' means an employee at the workplace, or another
individual approved by the employer, who possesses the skills and
knowledge to be mastered by a student, and who instructs the student,
critiques the student's performance, challenges the student to perform
well, and works in consultation with classroom teachers and the
employer.
Absolute Priority
Under 34 CFR 75.105(c)(3), the Secretaries of the Departments of
Education and Labor give an absolute preference to applications that--
(a) Are submitted by States; and
(b) Propose to implement statewide School-to-Work Opportunities
plans that are included in the applications and that--
(1) Designate the geographical areas to be served by partnerships,
which shall, to the extent feasible, reflect local labor market areas;
(2) Describe the manner in which the Governor; the State
educational agency; the State agency officials responsible for job
training and employment, economic development and postsecondary
education; and other appropriate officials, will collaborate in the
implementation of the State School-to-Work Opportunities system;
(3) Describe the manner in which the State has obtained and will
continue to obtain the active and continued involvement in the
statewide School-to-Work Opportunities system of employers and other
interested parties such as locally elected officials, secondary and
postsecondary educational institutions or agencies, business
associations, employees, labor organizations or associations thereof,
teachers, related services personnel, students, parents, community-
based organizations, rehabilitation agencies and organizations,
registered apprenticeship agencies, human services agencies, language
minority communities, Private Industry Councils established under the
Job Training Partnership Act, vocational student organizations, State
or regional cooperative education associations, and local vocational
educational agencies;
(4) Describe the manner in which the School-to-Work Opportunities
system will coordinate with or integrate local school-to-work programs,
including programs financed from State and private sources with funds
available from related Federal programs such as the Adult Education Act
(20 U.S.C. 1201 et seq.), the Carl D. Perkins Vocational and Applied
Technology Education Act (20 U.S.C. 2301 et seq.), the Elementary and
Secondary Education Act of 1965 (20 U.S.C. 2701 et seq.), the Higher
Education Act of 1965 (20 U.S.C. 1001 et seq.), part F of title IV of
the Social Security Act (42 U.S.C. 681 et seq.) (authorizing the Job
Opportunity Basic Skills Training Program), the Goals 2000: Educate
America Act, the Individuals with Disabilities Education Act (20 U.S.C.
1400 et seq.), the Job Training Partnership Act (29 U.S.C. 1501 et
seq.), the National Apprenticeship Act (29 U.S.C. 50 et seq.), the
Rehabilitation Act of 1973 (29 U.S.C. 701 et seq.), and the National
and Community Service Act of 1990 (42 U.S.C. 12501 et seq.);
(5) Describe the State's strategy for providing training for
teachers, employers, mentors, counselors, and other parties involved in
the State's School-to-Work Opportunities System;
(6) Describe the resources, including private sector resources, the
State intends to employ in maintaining the State's School-to-Work
Opportunities system when Federal School-to-Work Opportunities funds
are no longer available;
(7) Describe how the State will ensure effective and meaningful
opportunities for all students to participate in School-to-Work
Opportunities programs;
(8) Describe the goals of the State and the methods the State will
use, such as awareness and outreach, to ensure opportunities for young
women to participate in School-to-Work Opportunities programs in a
manner that leads to employment in high-performance, high-paying jobs,
including non-traditional employment;
(9) Describe how the State will ensure opportunities for low-
achieving students, students with disabilities, and former students who
have dropped out of school to participate in School-to-Work
Opportunities programs in a manner that leads to employment in high-
performance, high-paying jobs;
(10) Describe the State's process for assessing the skills and
knowledge required in career majors, and awarding skill certificates
that take into account the work of the proposed National Skill
Standards Board and the criteria established under the Goals 2000:
Educate America Act;
(11) Describe the performance standards that the State intends to
meet;
(12) Designate a fiscal agent to receive and be accountable for
School-to-Work Opportunities funds awarded under the program; and
(13) Describe how the State will stimulate and support local
School-to-Work Opportunities programs that meet the requirements of
this notice and how the State's system will be expanded over time to
cover all geographic areas in the State, including those with high
concentrations of poor and disadvantaged youth.
General Program Requirements
A School-to-Work Opportunities program under this priority must
include the following common features and basic program components:
(a) The basis of the School-to-Work Opportunities system is--
(1) The integration of work-based learning and school-based
learning, that provides students, to the extent practicable, with broad
instruction in all aspects of the industries students are preparing to
enter;
(2) The integration of occupational and academic learning; and
(3) The linking of secondary and postsecondary education.
(b) School-to-Work Opportunities programs will result in students
attaining--
(1) A high school diploma, or its equivalent;
(2) A certificate or diploma recognizing successful completion of
one or two years of postsecondary education, if appropriate; and
(3) A skill certificate.
(c) School-to-Work Opportunities programs must incorporate three
basic program components:
(1) Work-Based Learning, that includes--
A planned program of job training and work experiences,
including pre-employment and employment skills to be mastered at
progressively higher levels, that are relevant to a student's career
major and lead to the award of a skill certificate;
Paid work experience;
Workplace mentoring;
Instruction in general workplace competencies.
(2) School-Based Learning, that includes--
Career awareness and career exploration and counseling
(beginning at the earliest possible age) in order to help students who
may be interested to identify, and select or reconsider, their
interests, goals, and career majors, including those options that may
not be traditional for their gender, race or ethnicity;
Initial selection by interested students of a career major
not later than the beginning of the 11th grade;
A program of study designed to meet the same challenging
academic standards developed by the State for all students including,
where applicable, standards established under the Goals 2000: Educate
America Act, and to meet the requirements necessary for a student to
earn a skill certificate; and
Regularly scheduled evaluations to identify academic
strengths and weaknesses, academic progress, workplace knowledge and
goals of students and the need for additional learning opportunities to
master core academic and vocational skills.
(3) Connecting Activities, that include--
Matching students with employers' work-based learning
opportunities;
Serving as a liaison among the employer, school, teacher,
parent, and student and, if appropriate, other community partners;
Providing technical assistance and services to employers,
including small and medium-sized businesses, and others, in designing
work-based learning components and counseling and case management
services, and in training teachers, workplace mentors, and counselors;
Providing assistance to students who have completed the
program in finding an appropriate job, continuing their education, or
entering into an additional training program;
Providing assistance to schools and employers to integrate
school-based and work-based learning and integrate academic and
occupational learning;
Collecting and analyzing information regarding post-
program outcomes of students who participate in the School-to-Work
Opportunities program which may include, information on gender, race,
ethnicity, socio-economic background, limited- English proficiency, and
disability; and
Linking youth development activities under the School-to-
Work Opportunities program with employer and industry strategies for
upgrading the skills of their workers.
Examples of Statewide Activities
Funds awarded under this program shall be expended by the grantee
only for activities undertaken to implement the State's School-to-Work
Opportunities system, which may include--
(a) Recruiting and providing assistance to employers to provide
work-based learning for students;
(b) Conducting outreach activities to promote and support
collaboration in School-to-Work Opportunities programs by businesses,
labor organizations, and other organizations, including stimulating the
development of partnerships in poor communities;
(c) Providing training for teachers, employers, workplace mentors,
counselors, related services personnel, and others;
(d) Providing labor market information to local partnerships that
is useful in determining which high-skill, high-wage occupations are in
demand;
(e) Designing or adapting model curricula that can be used to
integrate academic and vocational learning, school-based and work-based
learning, and secondary and postsecondary education;
(f) Designing or adapting model work-based learning programs and
identifying best practices;
(g) Conducting outreach activities and providing technical
assistance to other States that are developing or implementing School-
to-Work Opportunities systems; and
(h) Working with localities to develop strategies to recruit and
retain all students in School-to-Work Opportunities programs, including
those from a broad range of backgrounds and circumstances.
Allocation of Funds to Local Partnerships
A grantee under this priority must award subgrants to local
partnerships in carrying out activities under the School-to-Work
Opportunities program, according to criteria established by the
grantee. Subgrants to local partnerships shall total no less than 65
percent of the sums awarded to each State in the first year, 75 percent
of the sums awarded to each State in the second year, and 85 percent of
such sums in each year thereafter.
A partnership that seeks support in carrying out a local School-to-
Work Opportunities program shall submit an application to the State
that--
(a) Describes how the local program would include the basic School-
to-Work Opportunities program components and otherwise meet the
requirements of this notice;
(b) Sets forth measurable program goals and outcomes;
(c) Describes the local strategies and timetables to provide
School-to-Work Opportunities program opportunities for all students;
and
(d) Provides such other information as the State may require.
Examples of Activities for Local Partnerships
Funds under this program that are used to support partnerships
shall be expended only for activities undertaken to carry out School-
to-Work programs as provided for in this notice, and such activities
may include--
(a) Recruiting and providing assistance to employers, including
small and medium-sized businesses, to provide the work-based learning
components in the School-to-Work Opportunities program;
(b) Establishing consortia of employers to support the School-to-
Work Opportunities program and provide access to jobs related to
students' career majors;
(c) Supporting or establishing intermediaries to perform the
connecting activities described above in paragraph (c)(3) under
``General Program Requirements'' and to provide assistance to students
in obtaining jobs and further education and training;
(d) Designing or adapting school curricula that can be used to
integrate academic and vocational learning, school-based and work-based
learning, and secondary and postsecondary education;
(e) Providing training to work-based and school-based staff on new
curricula, student assessments, student guidance, and feedback to the
school regarding student performance;
(f) Providing career exploration and awareness services, beginning
at the earliest possible age, including counseling and mentoring
services, college awareness and other services to prepare students for
the transition from school to work;
(g) Establishing in schools participating in a School-to-Work
Opportunities program a graduation assistance program to assist at-
risk, disabled, and low-achieving students in graduating from high
school, enrolling in postsecondary education or training, and finding,
maintaining, or advancing in jobs;
(h) Conducting or obtaining an in-depth analysis of the local labor
market and the generic and specific skill needs of employers to
identify high-demand, high-wage careers to target;
(i) Integrating work-based and school-based learning into existing
job training programs for youth who have dropped out of school;
(j) Establishing or expanding school-to-apprenticeship programs in
cooperation with registered apprenticeship agencies and apprenticeship
sponsors;
(k) Assisting participating employers, including small- and medium-
size businesses, to identify and train workplace mentors and to develop
work-based learning components;
(l) Designing local strategies to provide adequate planning time
and staff development activities for teachers, school counselors, and
related services personnel;
(m) Enhancing linkages between after school, weekend, and summer
jobs, and opportunities for career exploration and school-based
learning; and
(n) Conducting outreach to all students in a manner that most
appropriately meets their needs and the needs of their communities.
Safeguards
The Secretaries apply the following safeguards to School-to-Work
Opportunities programs funded under this priority:
(a) No student shall displace any currently employed worker
(including a partial displacement, such as a reduction in the hours of
non-overtime work, wages, or employment benefits).
(b) No School-to-Work Opportunities program shall impair existing
contracts for services or collective bargaining agreements, except that
no program under this priority that would be inconsistent with the
terms of a collective bargaining agreement shall be undertaken without
the written concurrence of the labor organization and employer
concerned.
(c) No student shall be employed or job opening filled--
(1) When any other individual is on temporary layoff from the
participating employer, with the clear possibility of recall, from the
same or any substantially equivalent job; or
(2) When the employer has terminated the employment of any regular
employee or otherwise reduced its workforce with the intention of
filling the vacancy so created with a student.
(d) Students shall be provided with adequate and safe equipment and
a safe and healthful workplace in conformity with all health, safety,
and labor standards of Federal, State, and local law.
(e) Nothing in this priority shall be construed so as to modify or
affect any Federal or State law prohibiting discrimination on the basis
of race, religion, color, ethnicity, national origin, gender, age, or
disability.
(f) Funds awarded under this priority shall not be expended for
wages of students.
(g) The grantee shall implement and maintain such other safeguards
as the Secretaries may deem appropriate in order to ensure that School-
to-Work Opportunities participants are afforded adequate supervision by
skilled adult workers, or, otherwise, to further the purposes of this
program.
An applicant must provide an assurance, in the application, that
the foregoing safeguards will be implemented and maintained throughout
all program activities.
Selection Criteria for Evaluating Applications
Under the School-to-Work Opportunities Implementation Grant
competition, the Secretaries will use the following selection criteria
in evaluating applications. The Secretaries will evaluate applications
using a two-phase review process. In the first phase of the review
process, the Secretaries will use peer reviewers to evaluate
applications using the selection criteria and the associated point
values. In the second phase, review teams will visit high-ranking
States to gain further information and further assess State plans. The
second-phase review teams will use the criteria, but not necessarily
the associated point values, in their information-gathering and
assessment activities. Final funding decisions made by the Secretaries
will be based on information gained during the site visits, the ranking
of applications during the first-phase review, and such other factors
as geographic balance and diversity of program approaches,
replicability, sustainability, and innovation.
(a) Comprehensive Statewide System. (25 points) Is the School-to-
Work Opportunities plan described in the application likely to produce
systemic statewide change that will have substantial impact on the
preparation of youth for a first job in a high-skill, high-wage career
and in increasing their opportunities for further education? Does the
plan provide information reflecting the needs of each local labor
market area in the designated geographic areas of the State? Does the
State propose a feasible plan for expanding the system to ensure that
all geographic areas of the State, including communities with high
concentrations of poor and disadvantaged youth, will have an
opportunity to participate in School-to-Work Opportunities programs
within a reasonable period of time? Is the process for assessing skills
and issuing skill certificates likely to lead to portable credentials
for students and are the skills adequately benchmarked to high quality
standards such as those envisioned in the Goals 2000: Educate America
Act? Does the State's process for assessing skills reflect the needs of
high performance workplaces and meet the requirements of broad clusters
of related occupations and industries, rather than those of individual
jobs or occupations? Has the State described State and local
performance standards that should lead to statewide systemic reform of
secondary education?
(b) Collaboration and Involvement of Key Partners. (25 points)
(1) State collaboration: Is there a vision for implementing a
statewide School-to-Work Opportunities system that is shared by the
Governor; the State educational agency; the State agency officials
responsible for job training and employment, economic development, and
postsecondary education; and other appropriate officials? Does the plan
substantially demonstrate sufficient commitment and specific
involvement of these partners in the statewide implementation? Are the
activities appropriate to the partners and likely to produce the
desired changes in the way students are prepared for the future? Is
there evidence that the State partners have the capacity to support the
statewide implementation?
(2) Involvement by key parties: Does the State plan include an
effective and convincing strategy for obtaining the active and
continued involvement of employers and other interested parties such as
locally elected officials, secondary and postsecondary educational
institutions or agencies, business associations, employees, labor
organizations or associations thereof, teachers, students, parents,
community-based organizations, rehabilitation agencies and
organizations, registered apprenticeship agencies, and local vocational
educational agencies in the implementation of statewide systems? Does
the strategy recognize the interests of the key parties and utilize
their strengths appropriately? Does the plan reflect the input of
employers and other key parties?
(c) Resources. (10 points) Is the plan for a comprehensive
statewide School-to-Work Opportunities system adequately supported by
other Federal, State, and local resources? Does the plan effectively
integrate State and private education and training resources with other
Federal education and training resources? Does the plan limit
administrative costs in order to maximize the amounts spent on delivery
of services to students enrolled in its School-to-Work Opportunities
programs? Is there an effective long-term plan for maintaining the
School-to-Work Opportunities system with resources other than Federal
School-to-Work Opportunities funds?
(d) Student Participation. (15 points) Does the plan propose
realistic strategies and programs to ensure that ``all students,''
including young women, minorities, low-achieving students, students
with disabilities, students with limited-English proficiency,
academically talented students, and former students who have dropped
out, have the opportunity to participate in School-to-Work
Opportunities programs? Does the strategy recognize barriers to their
participation and propose effective ways of overcoming them so that
these students are prepared for high-skill, high-wage jobs including,
for young women and minorities non-traditional employment?
(e) Local Programs. (15 points) Does the plan include an effective
strategy for supporting local School-to-Work Opportunities programs
that integrate occupational and academic learning, integrate work-based
and school-based learning, establish linkages between secondary and
postsecondary education, include components for work-based learning,
school-based learning and connecting activities, and result in the
award of a high school diploma or its equivalent, a certificate or
diploma recognizing successful completion of one or two years of
postsecondary education (if appropriate), and a skill certificate? Have
promising existing programs been considered for adaptation? Have new
directions and approaches been planned to ensure that these programs
meet the priority? Does the plan show evidence that local School-to-
Work Opportunities programs throughout the State, including those that
have been funded by the Department of Education or the Department of
Labor, are an effective part of a statewide School-to-Work
Opportunities system?
(f) Management Plan. (10 points) Does the entity submitting the
application on behalf of the State have the capacity to manage the
implementation of a comprehensive statewide School-to-Work
Opportunities system? Does the State's management plan anticipate
barriers to statewide implementation and include a system for
addressing them as they arise? Does the management plan include a
process for incorporating methods to improve or redesign the
implementation system based on program outcomes, for example through an
evaluation plan? Will the State's performance standards be applied to
local partnerships and will the standards be used to evaluate and
improve their outcomes? Are key personnel under the plan qualified to
perform the required activities, particularly to maintain the essential
partnerships at the State level in a manner sufficient to implement the
plan? Will Federal funds under the School-to-Work Opportunities Program
grant be used to support partnerships that seek to carry out local
School-to-Work Opportunities programs?
Other Factors
In addition to considering the factor of geographic distribution
authorized under 34 CFR 426.25 of the Cooperative Demonstration program
regulations, prior to making final funding decisions, the Secretaries
also will consider as a factor the diversity of approaches to School-
to-Work Opportunities proposed by each applicant.
Intergovernmental Review
This program is subject to the requirements of Executive Order
12372 and the regulations in 34 CFR part 79. The objective of the
Executive order is to foster an intergovernmental partnership and a
strengthened federalism by relying on processes developed by State and
local governments for coordination and review of proposed Federal
financial assistance.
In accordance with the order, this document is intended to provide
early notification of the Department's specific plans and actions for
this program.
Applicable Program Regulations: 34 CFR parts 400 and 426.
Program Authority: 20 U.S.C. 2420a.
(Catalog of Federal Domestic Assistance Number 84.199-H Cooperative
Demonstration Program)
Dated: January 25, 1994.
Richard W. Riley,
Secretary of Education.
Robert B. Reich,
Secretary of Labor.
Appendix--Analysis of Comments and Changes
General
Comment: One commenter noted that Congress is currently debating
the exact requirements for programs under the proposed School-to-Work
Opportunities bill and expressed the belief that States are not
immediately prepared to implement Statewide plans and systems. The
commenter suggested that it would be preferable to extend the comment
period for this notice until after Congress has agreed to the statutory
program requirements. The commenter suggested that if the Departments
choose to award implementation grants prior to the enactment of School-
to-Work Opportunities legislation, they would have the authority to
include provisions not contained in the original Administration bill
nor, indeed, in the House or the Senate versions, so long as these
provisions are consistent with the broad provisions for the Cooperative
Demonstration Program authorized under section 420A of the Perkins Act,
and 34 CFR 426.4, under which the funds for this competition were
appropriated.
Discussion: The Secretaries do not agree that the comment period
should be extended until the School-to-Work Opportunities bill is
enacted into law by Congress. Indicative of Congressional intent to
allow States and localities to begin establishing School-to-Work
Opportunities systems, Congress has appropriated funds under existing
authority for this fiscal year 1994 competition. The Secretaries wish
to award grants as soon as possible after July 1, 1994, when the funds
become available, so that the States that compete successfully for
those funds may have School-to-Work Opportunities systems operating in
the 1994-95 school year. Waiting until enactment to publish a notice
inviting applications would inevitably result in significant delays in
both awarding funds and initiating programs and activities. At the same
time, however, the Secretaries want to make certain that, to the
greatest extent practicable, this priority reflects the most current
Congressional action to date on the pending legislation. Accordingly,
where provisions of the House and Senate bills are identical and differ
from the provisions in the proposed notice, and where the House and
Senate modifications are consistent with relevant existing authorities,
the Secretaries have reflected those modifications in this final
notice.
Changes: Changes have been made in the notice to reflect House and
Senate modifications to the proposed School-to-Work Opportunities
legislation, where those changes are consistent with relevant existing
statutory authorities.
Comment: One commenter stated that, because the Federal Government
already carries out the function of career education through the
National Occupational Information Coordinating Committee, the
Secretaries should add a fourth Federal role to the three already
delineated in the ``Background'' section of the notice, ``to assist
States in the provision of accurate and timely occupational and career
development information for purposes of program planning, career
guidance and counseling, and individual career exploration, choice and
educational planning.''
Discussion: The Federal role that is delineated in the
``Background'' section of the October 14, 1993 notice is a broad
characterization of the Federal role envisioned by the Secretaries. The
``Background'' section is not meant to delineate each of the ways in
which the Federal Government might assist States or localities to
implement school-to-work systems. Counseling and integrating existing
Federal, State, and local programs into comprehensive School-to-Work
Opportunities systems is clearly of vital importance to the national
School-to-Work Opportunities framework and are embodied in the criteria
in this notice as well as in the pending legislation. Although it is
not the Secretaries' intent to recount all possible Federal roles here,
the Secretaries have added reference to a fourth Federal role, that of
creating a national School-to-Work Opportunities framework through
common core criteria and national standards. The Secretaries believe
that the Federal role referred to by the commenter is implicit in this
notice.
Changes: Reference to an additional Federal role, that of creating
a national School-to-Work Opportunities framework, has been added to
``Background'' section of this notice.
Comment: One commenter thought that the final priority should give
preference to, and thereby require applications to identify a
significant portion of the funds available for local systems for use in
high poverty areas.
Discussion: The competition covered by this notice is for State
grants only. From grants received under this competition, grantees will
distribute a substantial amount of funds to localities, including high
poverty areas. Each State must demonstrate in its plan how it will
ensure opportunities for ``all students'' to participate in the
program. In addition, each State will be required to describe how its
School-to-Work Opportunities system will be expanded to cover all
geographic areas, including high poverty areas. The Departments will
soon announce a separate direct grant program for local projects
located in high poverty areas.
Changes: None.
Comment: One commenter believed that it was unclear from the notice
whether there are clear vehicles for the Federal Government to help
States and localities learn from each other and from the experience of
international competitors, and to build a knowledge base of effective
school-to-work models. Therefore, the commenter suggested that the
notice be modified to include a separate grant program or a contract to
support the Federal Government in achieving these roles.
Discussion: This notice relates only to the School-to-Work
Opportunities State grants competition. However, other funds will be
available under the fiscal year 1994 appropriation for Federal level
activities, such as technical assistance and research and development,
that will help States and localities learn from each other and from the
experiences of our international competitors, and that will help States
build a knowledge base of effective school-to-work models. The
Secretaries do not envision one separate grant or contract for
achieving these purposes, but plan to utilize the broad range of
vehicles available to them.
Changes: None.
Comment: One commenter noted that very little institutional
structure is available in the United States that could manage the
partnerships anticipated, and suggested awarding a separate seed grant
to a local body not politically tied to any one of the stakeholders for
this purpose.
Discussion: The Secretaries believe that States and local
communities can best determine how to form and govern the partnerships
required under this program. A local partnership can determine for
itself which entity in that community is best equipped to manage the
partnership. Thus, the Secretaries see no need for the separate direct
Federal grants recommended by the commenter.
Changes: None.
Comment: One commenter noted that certificates and credentials in
the United States are linked to limited, very defined jobs, such as
``radiology,'' and not to sets of skills that integrate knowledge
across an industry. The commenter suggested that the States will need
to overhaul their current approach to certification and credentialing
if this definition is to be realized.
Discussion: It is the Secretaries' intent that States design
School-to-Work Opportunities programs of high quality that will prepare
students to become part of a high-performance workforce and that will
lead to skill certificates as one of the outcomes of participation.
Until there is a system of national skill standards, States are
encouraged to apply the highest standards and certifications available.
During this period, the Departments will be assisting States in
identifying sources and means by which to access existing high quality,
industry-recognized standards and accompanying assessment tools, as
well as assisting States to collaborate effectively with each other
toward the development of high quality skill standards. Once the
National Skill Standards Board begins its work, and even before there
are skill standards actually endorsed by the Board, States will be
required to take the work of the Board into consideration in their
development of standards for skill certificates, as is likely to be
required under the proposed School-to-Work Opportunities legislation.
This is intended to facilitate the development of national, portable
credentials and to avoid unnecessary duplication and overlap.
Changes: None.
Subgrants to Local Partnerships
Comment: One commenter recommended that ``currently applicable
Federal laws'' that would allow States to fund local partnerships
should be specified in the final notice. The commenter noted that
without this specific information, States would be unable to award
grant funds to local partnerships.
Discussion: Authority for States to award subgrants to local
partnerships is now contained in the 1994 Department of Education
Appropriation Act. Accordingly, the notice clearly provides that States
receiving School-to-Work Opportunities implementation grants must
distribute to local partnerships 65 percent of the amounts received in
the first year, 75 percent of the amount received in the second year,
and 85 percent of the amount received in each year thereafter.
Changes: The notice has been modified to reflect the subgrant award
authority provided in the 1994 Department of Education Appropriation
Act.
Peer Review
Comment: Two commenters made suggestions regarding peer reviewers
for this competition. One commenter said that the notice should require
peer reviewers to represent all the entities that could be members of
partnerships at the State level for development and administration of
School-to-Work Opportunities systems, including representatives from
secondary education, postsecondary education, employment, job training,
and economic development. The second commenter recommended that the
Secretaries include either individuals with disabilities or members of
their families on the review panels.
Discussion: The Secretaries wish to assure the commenters that they
plan to select peer reviewers carefully, based on experience,
education, training, and expertise in areas relevant to School-to-Work
Opportunities systems, and will seek to have as broad a representation
as possible on the review panels. However, specific requirements or
criteria for the selection of peer reviewers is outside the purpose and
scope of this notice.
Changes: None.
Definitions--``All Students''
Comment: One commenter expressed confusion about the meaning of the
term ``all students,'' as defined in the October 14, 1993 notice. The
commenter recommended that, if the Secretaries intended the term to
mean all students rather than a representative sub-sample of students,
the definition should be clarified by using the phrase ``all students
from the broad range of backgrounds'' in lieu of the phrase ``students
from the broad range of backgrounds.''
Discussion: The Secretaries intend the definition of ``all
students'' to be broadly inclusive of diverse groups within the
Nation's student population, including youth who have dropped out of
school. The definition in the notice should not be interpreted as
meaning a representative sub-sample of students.
Change: None.
Comment: One commenter noted that the term ``all students'' does
not appear to include out-of-school youth. The commenter stated that
excluding dropouts from the definition will result in the exclusion of
millions of young people from eligibility to participate in the School-
to-Work Opportunities program, including, for example, over one-third
of Hispanic youth of high school age.
Discussion: The Secretaries agree with the commenter that the
definition of the term ``All students'' should include youth who are
high school dropouts. Similarly, the Secretaries anticipate that, in
the final version of the School-to-Work Opportunities legislation, this
term will be defined as including students who have dropped out of
school.
Changes: The definition of the term ``All students'' has been
changed to include students who have dropped out of school.
Comment: Two commenters expressed concern with the extent to which
States would be required to provide for the participation of students
from disadvantaged backgrounds in their School-to-Work Opportunities
programs. One commenter expressed the view that if ``all students'' are
intended to be successful in the School-to-Work Opportunities
initiative, the notice should require or acknowledge the need for
considerably more effort and resources to be devoted to female students
and to students from disadvantaged backgrounds. Another commenter felt
that the notice should include language emphasizing inclusive projects,
that is, that the school-to-work needs of all students should be
addressed, not simply the needs of mainstream children without special
needs.
Discussion: The definition of the term ``All students'' in this
notice includes a number of population groups with special needs. Among
these are disadvantaged students, students with disabilities, students
with limited-English proficiency, and former students who have dropped
out of school. Moreover, under the ``Student Participation'' selection
criterion, reviewers will assess the extent to which States propose
realistic strategies and programs to demonstrate that ``all students,''
including young women, minorities, and low achieving students, have the
opportunity to participate in the State's School-to-Work Opportunities
program. The notice also requires that State plans address how States
will provide opportunities for all students to participate in School-
to-Work Opportunities programs. The Secretaries agree, however, that an
additional question in the selection criteria would help evaluators
assess the extent to which States have also addressed the needs of
students from communities with high concentrations of poor and
disadvantaged youth. Similarly, the Secretaries have concluded that the
priority should include a specific reference to communities with high
concentrations of poor and disadvantaged youth. Thus, the Secretaries
have revised the notice to require States to indicate specifically in
their plans how all students, including women, minorities, low
achieving students, and students from communities with high
concentrations of poor and disadvantaged youth, will have an
opportunity to participate in each State's proposed School-to-Work
Opportunities program. The Secretaries have also revised the selection
criterion to consider whether States propose feasible plans to include
communities with high concentrations of poor and disadvantaged youth in
the system.
Changes: Paragraph (b)(13) of the priority and the ``Comprehensive
Statewide System'' selection criterion have been modified to require
States to describe in their plans how the States' proposed School-to-
Work Opportunities systems will address the needs of students from
communities with high concentrations of poor and disadvantaged youth.
Comment: One commenter expressed the view that the current School-
to-Work Opportunities initiative deals only with students who are not
likely to enroll in college. The commenter suggested that, in order to
avoid tracking, clearly articulated 2+1, 2+2, and 2+2+2 programs would
be preferable in that they would allow students to exercise a variety
of options in both employment and educational environments.
Discussion: The School-to-Work Opportunities program is not
intended to be limited to only certain categories of students. The
definition of ``all students'' specifically includes students from a
broad range of backgrounds and circumstances, including academically
talented students. The notice establishes that career majors would
typically include two years of secondary school as well as one or two
years of postsecondary education. And, as part of their participation
in a School-to-Work Opportunities program, students who are completing
their first or second years at the postsecondary level would be
prepared to take advantage of options in employment and education,
including enrollment in a college or university bestowing a four-year
degree. However, the Secretaries agree with the commenter that the
definition should be revised to clarify that admission into such a
college or university is just one of the options available to
participating students to which a career major may lead.
Changes: Paragraph (e) of the definition of ``Career major'' has
been revised by adding the clause ``or admission into a degree-granting
college or university.''
Definitions--All Aspects of an Industry (Previously ``Elements of the
Industry'')
Comment: Two commenters raised questions relative to the definition
of ``Elements of the industry,'' as used in the proposed priority
notice. One commenter thought that the proposed definition of
``Elements of the industry'' did not promote the kind of thorough and
challenging understanding of all aspects of an industry that are
necessary for the School-to-Work Opportunities initiative to be
successful in transforming the future American labor force. Instead,
the commenter stated a preference for the language in the Carl D.
Perkins Vocational and Applied Technology Education Act that requires
students to be provided with an understanding of ``all aspects of an
industry.'' The second commenter believed that the term ``industry''
would be poorly understood and that the term should be defined as a
collection of employers who share common requirements for human and
physical capital, such as the aerospace industry, etc.
Discussion: The Secretaries agree that it is preferable for the
term utilized in this notice to be consistent with the term utilized in
the Carl D. Perkins Vocational and Applied Technology Education Act.
Moreover, the term ``All aspects of the industry'' also appears in both
the Senate and House bills of the School-to Work Opportunities bills
currently under consideration by Congress. Therefore, the Secretaries
have eliminated the term ``Elements of the industry'' from the notice,
and have substituted the term ``All aspects of the industry.'' However,
the Secretaries feel that the term ``industry'' is clear in the context
of this definition, and need not be further defined in this notice.
Changes: The term ``Elements of the industry'' has been replaced by
the term ``All aspects of the industry'' for the purpose of achieving
consistency with the proposed School-to-Work Opportunities legislation,
as well as with the Carl D. Perkins Vocational and Applied Technology
Education Act. Likewise, the definition of the term ``all elements of
the industry'' has been replaced with the definition of ``all aspects
of the industry'' from the regulations implementing the Perkins Act, at
34 CFR 400.4(b).
Definitions--Career Major
Comment: Two commenters expressed the view that, when coupled with
the examples of local partnership activities contained in the notice,
the proposed definition of the term ``Career major'' suggests that the
School-to-Work Opportunities initiative will not recognize a high
school equivalency diploma as being equivalent to the attainment of an
actual high school diploma. These commenters recommended that the
definition of a ``Career major'' be amended to better accommodate out-
of-school youth by including both passage of a high school equivalency
test and the high school diploma, as acceptable outcomes of
participation in School-to-Work Opportunities programs.
Discussion: The Secretaries agree with the commenters that, in
part, the attainment of an equivalency diploma by a former student who
has participated in, and completed, a School-to-Work Opportunities
program, would be an acceptable outcome of such participation.
Changes: The definition of the term ``Career major'' has been
modified to include an ``equivalent'' certificate. (Parallel changes
have been made in the ``General Program Requirements'' section of the
notice and the ``Local Programs'' selection criterion.)
Comment: One commenter stated that, while a four-year degree is not
the primary focus or goal of the School-to-Work Opportunities
initiative, it should be considered an appropriate outcome of
participation in a School-to-Work Opportunities program. The commenter
felt that course work should be sufficiently rigorous and linked to
higher education academic requirements so a student could enter into a
four-year academic program following participation in the program. This
commenter suggested that the term, ``or enrollment in a Bachelor's
degree program'' be added to the end of the last sentence in the
definition of the term ``career major.''
Discussion: The Secretaries agree with the reasoning provided by
the commenter, as discussed above.
Changes: Paragraph (e) of the definition of the term ``career
major'' has been revised by adding the clause ``or admission into a
degree-granting college or university'' so as to clarify that, among
other things, completion of a career major may result in admission into
a degree-granting college or university.
Comment: One commenter stated that the proposed definition of a
``career major'' included criteria that would result in an automatic
barrier preventing many students with disabilities from benefitting
from a School-to-Work Opportunities program. This commenter felt that,
in most school systems, students participating in special education
programs continue to receive certificates in lieu of a high school
diploma and that one or two additional years of training past high
school should be an acceptable outcome for many of these learners in
lieu of one or two years of postsecondary education. The commenter
recommended that the definition of the term ``career major'' be revised
in specific ways to accommodate and encourage the participation of
special education students.
Discussion: The Secretaries do not intend to discourage the
participation of students with disabilities in State School-to-Work
Opportunities programs. Indeed, the School-to-Work Opportunities
initiative is intended to serve all students, as has already been
discussed. Moreover, the Secretaries agree with the commenter that many
States already provide equivalent diplomas or certificates to disabled
students. Accordingly, the Secretaries intend to include within the
term ``equivalent,'' which has been added to the definition of the term
``Career major,'' certificates provided by States to students with
disabilities, that are considered to be equivalent to high school
diplomas.
Changes: The definition of ``Career major'' has been revised to
include reference to the ``equivalent'' of a high school diploma.
Comment: One commenter felt that two years of secondary school and
one or two years of post-secondary education would be too great a time
commitment for many disadvantaged youth, particularly dropout youth. In
the opinion of the commenter, disadvantaged youth with children or
disadvantaged youth supporting themselves financially, necessarily
require a faster route to employment. Accordingly, the commenter
suggested that ``one plus one,'' or a condensed one year program, would
better serve their needs.
Discussion: The Secretaries believe that directing disadvantaged
youth to abbreviated versions of the high quality programs being
provided to all other students would serve only to short-change the
disadvantaged students since abbreviated programs would fail to provide
participants with the qualifications needed to obtain high-skill, high-
wage employment. A high school diploma and, often, one or two years of
further education or training are required for students to obtain the
kinds of high-skill, high-wage employment envisioned by the School-to-
Work Opportunities initiative. It is important to note also that paid
work experience--which is a basic program requirement of the School-to-
Work Opportunities program's work-based learning component--can also
serve to provide some amount of income to participating disadvantaged
students. The students are also eligible for additional services under
other programs such as the Job Training Partnership Act. Moreover,
under this program, States and local partnerships retain the
flexibility to develop innovative supportive services for disadvantaged
students participating in School-to-Work Opportunities programs geared
toward further assisting them to meet their financial and other needs.
Changes: None.
Definitions--Partnership
Comment: Four commenters believed that the participation of
community-based organizations (CBOs) should be required in program
planning, implementation, and evaluation and, that to accomplish this,
the term ``Partnership'' should be redefined to ensure that CBOs are
not left out due to a definition that appears to make their involvement
optional. A fifth commenter recommended that the definition of
``Partnership'' be modified to require the participation of ``teachers
and related services personnel'' as a part of each partnership. The
commenter believed that this was necessary to encourage the
participation of certain individuals (including rehabilitation
counselors, school counselors, psychologists, speech and language
pathologists, audiologists, and social workers), who the commenter
believes are necessary to the successful participation of students with
disabilities in the School-to-Work Opportunities program.
Discussion: The Secretaries agree with the commenters that CBOs
will make important contributions to program planning, implementation,
and evaluation of School-to-Work Opportunities programs and encourage
partnerships to include them. Indeed, the Secretaries believe that most
localities will choose to include CBOs because of the value that they
are likely to bring to local partnerships. The Secretaries also believe
that teachers and related services personnel are likely to be helpful
as members of partnerships, and encourage localities to include them to
the extent possible. However, the Secretaries are opposed to requiring
the participation in all partnerships of either CBOs or teachers and
related services personnel, and continue to believe that localities
should be allowed to determine the membership in partnerships of
entities or groups outside of those whose membership is specifically
mandated through the notice's definition of the term ``Partnership.''
Changes: None.
Comment: One commenter felt that the definition of the term
``Partnership'' appeared to call for the establishment of a separate
local entity instead of a simple collaboration of entities and believed
this to be an unnecessary bureaucratic layer.
Discussion: Within the parameters and requirements specified in the
notice, States and localities will determine whether partnerships are
to be separate local entities or whether they are to consist of simple
collaborations of existing entities or groups. The Secretaries do not
intend the notice to require another bureaucratic layer or entity.
Changes: None.
Definitions--Skill Certificate
Comment: One commenter believed that the definition of the term
``Skill certificate'' would impose a barrier for students with
disabilities and would encourage their exclusion from States' School-
to-Work Opportunities programs. The commenter suggested that the
definition be changed to read, ``a portable, industry-recognized
credential issued by a program that certifies that a student has
mastered skills at levels that, to the extent feasible, are at least as
challenging as the standards endorsed by the National Skill Standards
Board.''
Discussion: As provided for in paragraph (b)(8) of the priority,
under the School-to-Work Opportunities program, States are required to
describe in their plans how they will ensure that students with
disabilities will have opportunities to participate in the States'
School-to-Work Opportunities programs. Under the ``Student
Participation'' selection criterion, States are required to propose
realistic strategies and programs to ensure that all students,
including students with disabilities, have opportunities to participate
in their States' School-to-Work Opportunities programs. The clause
``ensuring opportunities to participate'' is intended to include
opportunities to achieve program outcomes, including a skill
certificate. While it is very important that individuals with
disabilities be provided with the necessary support to ensure that they
have the opportunity to participate, the Secretaries do not see the
need to modify the definition of the term ``Skill certificate'' to
provide for different skill levels for students with disabilities, than
those provided for students without disabilities.
Changes: None.
Definitions--State
Comments: Five commenters noted that the term ``State'' is not
defined in the notice. They suggested that, to avoid confusion, the
term ``State'' should be defined as ``each of the several States, the
District of Columbia, and the Commonwealth of Puerto Rico.''
Discussion: The applicable definition of the term ``State'' is
contained in section 521(33) of the Carl D. Perkins Vocational and
Applied Technology Education Act, as implemented by Sec. 400.4(b) of
the Perkins regulations.
Changes: None.
Definitions--Workplace Mentor
Changes: None.
Comment: One commenter suggested that the workplace mentor was a
critical link within the School-to-Work Opportunities program and was
likely to require special training in order to fulfill this role
effectively. The commenter viewed the workplace mentor as being a
pedagogue with technical knowledge of the employment areas of interest
to the students participating in the program. The commenter felt that
greater consideration should be given under this program to training of
workplace mentors and that this could best be achieved under a separate
grant program.
Discussion: Under this priority, State and local partnerships may
utilize implementation grant funds to train workplace mentors to ensure
that they are knowledgeable in the employment areas that School-to-Work
Opportunities students are engaged in and to ensure that the mentors
have the necessary knowledge of the work-based curriculum as well as
other program policies and practices. Because the Secretaries believe
that partnerships should be able to customize programs to meet the
needs of local communities, including those of employers and students,
they do not believe that a separate grant program is necessary to
providing the proper training for workplace mentors.
Changes: None.
Comment: One commenter believed the definition of the term
``Workplace mentor'' should be changed to include ``other individuals
approved by the employer'' to be included as a workplace mentor so that
individuals such as special educators, vocational rehabilitation
counselors, job coaches, and work-study coordinators could serve in
this capacity for youth with disabilities.
Discussion: The Secretaries agree with the commenter's suggestion.
Changes: The definition of ``Workplace mentor'' has been modified
to include ``another individual approved by the employer.''
Priority--General
Comments: Two commenters suggested that the Secretaries consider
awarding School-to-Work Opportunities grants on a priority basis to:
(1) Areas with high levels of unemployment, (2) areas that are impacted
by military base closures, and (3) areas that are experiencing cutbacks
in defense spending or conversions from defense manufacturing. One of
the commenters also suggested that the Secretaries consider awarding
grants under this competition based on priorities addressing new and
emerging technologies and displaying ``complete vertical integration
from start to partnering and productive employment placement.''
Similarly, the second commenter felt that priority should be extended
to areas of economic need that can greatly benefit from additional
coordinated funding such as that available under the National and
Community Service Act. A third commenter felt that priority should be
given to communities with high concentrations of poor and disadvantaged
youth.
Discussion: The purpose of this award is to provide funds to States
to develop statewide School-to-Work Opportunities systems. The State
plan must describe how the State will stimulate and support local
School-to-Work Opportunities programs and how the State system will be
expanded over time to cover all geographic areas in the State including
those with high concentrations of poor and disadvantaged youth. States
must also distribute a significant portion of their grant funds to
local partnerships (65 percent in the first year, 75 percent in the
second year, and 85 percent in the third year.) Within this context,
States and localities have the flexibility to determine those areas
that should receive priority in the establishment of statewide systems
and for receipt of funds. While the Secretaries recognize the value of
directing School-to-Work Opportunities funds to all of the areas named
by the commenters, the Secretaries are opposed to mandating to States
that these areas receive funds on a priority basis. Although they have
not established a priority for such communities, in response to the
third commenter's concerns about communities with high concentrations
of poor and disadvantaged youth, the Secretaries have made a change.
Changes: The notice has been modified to include the requirement in
both paragraph (b)(13) of the priority and in the ``Comprehensive
Statewide System'' selection criterion that States provide
opportunities for participation in their School-to-Work Opportunities
programs by students in all parts of each State, including communities
with high concentrations of poor and disadvantaged youth.
Priority--Eligibility and Absolute Preference to State Applications
Comment: One commenter stated that making States responsible for
School-to-Work Opportunities programs made sense for most populations
but not necessarily for migrant or seasonal farmworkers. The commenter
felt that what he referred to as ``State-run initiatives'' sometimes
fail to include services for these populations since they are often
considered to be a national population. In the commenter's view, even
where States are aware that farmworkers live within their boundaries,
States often do not have the special expertise needed to provide these
populations with services, or may not be able to serve the full range
of the farmworker population. The commenter suggested that the
Secretaries encourage States to take the unique needs of farmworker
youth into account as States develop their comprehensive statewide
School-to-Work Opportunities plans.
Discussion: Secondary students from farmworker and migrant
populations are included within the definition of ``all students.''
``All students'' is defined to mean ``students from a broad range of
backgrounds and circumstances, including disadvantaged students,
students of diverse racial, ethnic, and cultural backgrounds * * *
students with limited-English proficiency * * * .'' The Secretaries
expect migrant and seasonal farmworker youth to be served under the
School-to-Work Opportunities Program. In further response to the
concerns of the commenter, the Secretaries strongly encourage States
with migrant and seasonal farmworker populations, to take the full
range of needs of migrant and seasonal farmworker youth into account in
developing their plans.
Changes: None.
Comment: One commenter stated that among the applications that
should be given absolute preference under this competition are
applications that describe: (1) How occupational and career development
information available through State Occupational Information
Coordinating Committees (SOICCs) and State Employment Security Labor
Market Information Units will be used for planning, guidance, and
career exploration purposes; and (2) the kinds of career development
assistance that will be made available to students, including guidance
and counseling, occupational and career information, portfolios, and
other educational planning tools, and the manner in which parents and
teachers will be brought into the career development aspects of the
School-to-Work Opportunities program.
Discussion: With regard to SOICCs and State Employment Security
Labor Market Information Units, the Secretaries agree that these could
be important sources of information for many States. However, it is
thought preferable to allow States the flexibility to determine what
are the best sources of information for their specific needs, as well
as the best methods of obtaining information important to their
programs. In response to the commenter's second point, the Secretaries
note that, in paragraph (b)(3) of the priority, States must describe
their ``procedure for obtaining the active and continued involvement in
the statewide School-to-Work Opportunities system of * * * teachers,
students, and parents * * *.'' The Secretaries have concluded that it
is preferable to allow each State the flexibility to determine both the
specific kinds of career development assistance that will be made
available to students and the specific manner in which parents and
teachers will be included in the career development aspects of the
School-to-Work Opportunities program.
Changes: None.
Comment: One commenter was of the opinion that community colleges
are in a good position to assist in linking secondary and postsecondary
institutions so as to improve the quality of what the commenter
referred to as co-op education programs. The commenter suggested that
community colleges should have the opportunity to apply for grants
under this program or to be designated as fiscal agents. Further, the
commenter suggested that, given the opportunity, community colleges
could serve effectively as centralized ``School-to-Work Program
Centers'' and could develop consortium arrangements between high
schools and employers.
Discussion: Under this competition, grants will be made to States
and each State will designate a fiscal agent. States, in turn, will
award subgrants to local partnerships that must include employers,
public secondary and postsecondary educational institutions or
agencies, and labor organizations or employee representatives. As
public postsecondary educational institutions, many community colleges
will qualify to participate in partnerships. Community colleges are
expected to play an important and active role in School-to-Work
Opportunities programs. The matter of which entity will serve as grant
recipient or fiscal agent at the State or local level will be decided
by States and local partnerships.
Changes: None.
Priority--Comprehensive Statewide System
Comment: One commenter believed that one goal of a School-to-Work
Opportunities system is not only to prepare youth for existing jobs but
also to enable them to gain access to growing sectors of the economy
likely to affect future markets. In the view of the commenter, States
should be encouraged to identify and incorporate into their plans those
geographical areas that are targeted for economic growth. The commenter
further stated that these would include areas that are either receiving
Federal, State, or local funds, or receiving funds from all of these
sources, for the purpose of stimulating their economies, or areas that
have been identified by local governmental or community based agencies
for economic activity.
Discussion: States are responsible for developing statewide School-
to-Work Opportunities systems. Each State plan must describe how the
State will stimulate and support local School-to-Work Opportunities
programs in the State, including in areas with high concentrations of
poor and disadvantaged youth. As part of this effort, States will, of
course, be encouraged to identify and incorporate in their plans,
geographic areas that are targeted for economic growth. However, the
Secretaries wish to reiterate that States and localities have the
flexibility to determine those areas that should receive any priority
in the establishment of statewide systems and for the receipt of funds
allocated to local partnerships.
Changes: None.
Priority--Collaboration To Implement the State School-to-Work
Opportunities System
Comment: One commenter requested that, in paragraph (b)(2) of the
priority, the phrase ``including State agency officials responsible for
special education, vocational rehabilitation, and other transition
services'' be added following the reference to ``other appropriate
officials.'' This commenter believed that all appropriate interagency
experts must be included in a collaborative effort toward
implementation of each State's School-to-Work Opportunities system.
Discussion: The Secretaries agree that the implementation of each
State's School-to-Work Opportunities system must be a collaborative
effort involving numerous officials within the State. Systemic change
and the provision of appropriate education, training, and employment
opportunities for all students cannot be achieved otherwise. However,
beyond specifying the involvement of the Governor, the State
educational agency, the State agency officials responsible for job
training and employment, economic development, and postsecondary
education as the priority does the Secretaries have opted not to
dictate to States which additional State officials must be included in
this collaborative effort. The Secretaries do, however, encourage the
collaboration of those officials named by the commenter and, in fact,
list ``rehabilitation agencies and organizations'' among those entities
which the State should actively involve in the implementation of
statewide systems.
Changes: None.
Priority--Active and Continued Involvement by Interested Parties
Comments: In addition to the interested parties specifically listed
in paragraph (b)(3) of the priority as those whose active and continued
involvement must be demonstrated in order for an application to be
given absolute priority, several commenters suggested that the
Secretaries add specific references to the following additional
interested parties: Language minority communities, Private Industry
Councils, related services personnel (such as vocational rehabilitation
counselors and job coaches) following the word ``teachers,'' and human
services agencies. One commenter suggested that teachers be moved to
the top of the existing list of interested parties in order to indicate
that priority will be assigned to applications placing priority upon
the cooperation of teachers. Two of the commenters were particularly
interested in ensuring the active and continued involvement of those
parties that are most critical to the preparation of disabled
populations for work and that are essential to the success of disabled
youth within the job setting.
Discussion: The Secretaries agree that the active and continued
involvement of each of the parties named by the commenters would be
entirely appropriate under paragraph (b)(3) of the priority notice, and
have revised paragraph (b)(3) accordingly. Specifically, with regard to
Private Industry Councils established under the Job Training
Partnership Act and with regard to vocational rehabilitation personnel,
the Secretaries wish to point out that, in the definition of the term
``partnership,'' these have been specifically named by the Secretaries
as parties that may be included within partnerships. In addition to the
parties suggested by the commenters, the House and Senate School-to-
Work Opportunities bills include vocational student organizations and
State or regional cooperative education associations to the list of
other interested parties. The Secretaries have added vocational student
organizations and State and regional cooperative education associations
to paragraph (b)(3) because the Secretaries consider these two entities
to be appropriate additions to the list of parties that may be involved
in the State School-to-Work Opportunities system, and to ease the
transition from funding under this Notice to funding under anticipated
School-to-Work Opportunities legislation. In adding the parties
suggested by the commenters and the parties in the House and Senate
bills, the Secretaries wish to emphasize that the list of other parties
in paragraph (b)(3) is purely illustrative of the types of parties
whose active and continued participation in a State's School-to-Work
system would be appropriate. Thus, while the Secretaries will place an
absolute priority upon applications that provide for the active and
continued involvement of employers and other interested parties, the
Secretaries have chosen to allow each State the flexibility to
determine which parties in addition to employers would most effectively
assist the State to implement its School-to-Work Opportunities system.
Changes: Section (b)(3) of the final priority has been revised to
add to the illustrative list of ``other interested parties'' the
following entities: Related services personnel, human services
agencies, language minority communities, Private Industry Councils
established under the Job Training Partnership Act, vocational student
organizations, and State or regional cooperative education
associations.
Comment: One commenter noted that the October 14, 1993 notice
contained no mention of how comprehensive high schools would be
involved and served under the School-to-Work Opportunities State
Implementation Grants program, suggesting the need for clarification on
the involvement of comprehensive high schools. The commenter was
concerned that changes were needed in order to ensure a viable role in
the program not merely for vocational high schools but also for
comprehensive high schools and recommended that references to
comprehensive high schools be added in paragraph (b)(3) of the priority
as well as in other parts of the notice where secondary schools are
discussed.
Discussion: The Secretaries fully intend that comprehensive high
schools be included in each statewide School-to-Work Opportunities
system. In order to implement a comprehensive School-to-Work
Opportunities system serving all students, States must ensure
opportunities for the participation of all students, including students
in comprehensive high schools. Under the School-to-Work Opportunities
program and under this priority, it would be unacceptable for only
vocational high schools, for example, to be included in a State's
implementation plan. However, the Secretaries believe that specific
reference to comprehensive high schools is unnecessary, since the term
``secondary'' encompasses all schools at the secondary level.
Changes: None.
Priority--Education and Training Funds Coordination
Comment: Under paragraph (b)(4) of the priority notice, each State
is required to describe how its comprehensive School-to-Work
Opportunities system will coordinate the use of funds available from
State and private sources with the use of funds available from other
Federal programs. One commenter suggested that a clause be added to
paragraph (b)(4) requiring the coordination of program activities
funded with State and private sources with Federal program funds. The
commenter also recommended that the JOBS program be specifically
listed.
Discussion: In response to the part of the comment suggesting that
a specific reference be added to paragraph (b)(4) to ``program
activities'' supported with State or private funds, the Secretaries
have concluded that such a reference is unnecessary. The requirement in
that paragraph is for coordination of the use of Federal education and
training funds. Included within the requirement articulated in
paragraph (b)(4), is the requirement for coordination between the
program activities supported with the State and private funds and the
program activities supported with funding received under related
Federal statutes. The Secretaries agree that the JOBS program should be
specifically listed. However, it is important to note that the list of
Federal programs in paragraph (b)(4) is not an exhaustive list of
related Federal programs with which the use of State and private funds
should be coordinated.
Changes: A specific reference to JOBS has been added to paragraph
(b)(4) of the priority notice.
Priority--Assessing Skills and Knowledge and Participation in the Goals
2000: Educate America Act
Comment: Several commenters stated that in paragraph (b)(9), which
requires States to describe their processes for assessing the skills
and knowledge required in career majors and in awarding skills
certificates that take into account the work of the proposed National
Skill Standards Board and the criteria established under the proposed
Goals 2000: Educate America Act, the priority ignores the fact that
participation in Goals 2000 is voluntary. One commenter noted that
requiring students to receive a skill certificate, as a common feature
of the program, assumes that the Goals 2000: Educate America Act, which
contains provisions for voluntary industry-based skill standards, will
be enacted into law. This commenter felt that it was inconsistent to
require a skill certificate based on enactment of a law which
establishes only voluntary, industry-based, skill standards.
Accordingly, the commenters suggested that language be added to this
paragraph of the priority notice, indicating that the standards or
criteria developed under Goals 2000 will only be required if the State
is participating in Goals 2000.
Discussion: An important goal of the School-to-Work Opportunities
program is to facilitate the employment of young Americans in high-
skill, high-wage occupations. Enhancing the ability of job applicants
to demonstrate that they possess high quality skills is one way to
promote access to such employment. A skill certificate can provide that
credential and thereby enhance job prospects. Therefore, the
Secretaries believe that this is a crucial component and should be a
required outcome. Participation in both the proposed Goals 2000 program
and the School-to-Work Opportunities program is entirely voluntary.
However, should a State elect to participate, the Secretaries expect
that skill certificates will be awarded and that they will take into
account the criteria proposed in Goals 2000 as well as the work of the
National Skills Standards Board. These criteria are intended to promote
the highest quality and most internationally competitive standards
possible, in order to facilitate high-wage, high-skill employment.
Changes: None.
Comment: One commenter supported the linking of skill certificates
to the National Skill Standards Board and observed that these standards
should be the direct goal of each State's efforts, otherwise the skills
standards would have little use. This commenter believed that the
standards should also be linked to the academic standards of the
National Council of Teachers of Math (NCTM) and the National Council of
Teachers of Science (NCTS).
Discussion: The Secretaries agree that input from the NCTM and NCTS
would be helpful and expect that they will be a part of the process
under which academic standards are set.
Changes: None.
Priority--Opportunities for All Students
Comments: Several commenters requested that the Secretaries expand
upon the requirement in paragraph (b)(6) of the October 14, 1993 notice
(redesignated as (b)(7) of this notice), under which States must
describe how they will ensure opportunities for participation for all
students. The commenters requested that this be done by requiring
States to describe how opportunities will be provided, particularly to
low-achieving, disabled, and limited-English proficient students. One
commenter noted that paragraph (b)(8) of the October 14, 1993 notice
should be redrafted in a manner similar to paragraph (b)(7) of the
October 14, 1993 notice, under which States were required to describe
the manner in which opportunities will be provided for young women to
participate in School-to-Work Opportunities programs in a manner
leading to meaningful employment opportunities.
Discussion: The Secretaries intend the requirement in paragraph
(b)(8), redesignated as (b)(9) of this notice, relating to low-
achieving students, students with disabilities, and dropouts, to
provide the same threshold for serving those students, as the language
in redesignated paragraph (b)(8) of the final priority, with regard to
serving young women. In both paragraphs, the Secretaries intend to seek
descriptions from States as to how they will ensure opportunities for
students to participate in a meaningful and productive manner in the
School-to-Work Opportunities program.
Changes: Paragraph (b)(9) has been changed to require each State to
describe how it will ensure opportunities for low achieving students,
students with disabilities, and former students who have dropped out of
school, to participate in School-to-Work Opportunities programs in a
manner that leads to employment in high-performance, high-paying jobs.
Comment: Three commenters requested, that in lieu of describing the
manner in which they will ``ensure'' opportunities for students to
participate in the School-to-Work Opportunities programs in paragraphs
(b)(6) through (b)(8) of the October 14, 1993 notice, States be
required to ``increase'' opportunities for students to participate in
the School-to-Work Opportunities programs.
Discussion: The Secretaries believe that requiring States to ensure
opportunities for student participation will naturally result in
increased opportunities for participation. Therefore, the Secretaries
do not think that the suggested change is necessary.
Changes: None.
Priority--Stakeholder Agreement
Comment: While agreeing that all the items in the notice are
critical, one commenter suggested that perhaps the most critical item
would be one requiring an agreement among ``stakeholders'' setting out
the results to be achieved by each State's program, how achievement of
these results would be determined by stakeholders, and what agency
would be entrusted with the review of program results. The commenter
suggested that an independent or quasi-independent entity would be best
suited for the role of evaluating program success.
Discussion: The Secretaries agree that the ideas presented by the
commenter, including that relating to agreements among stakeholders,
are good ones. While the Secretaries think that stakeholder agreements
may be very effective ways of ensuring meaningful collaboration, they
are opposed to making them mandatory. Rather, each State is allowed the
flexibility to determine the best way to ensure effective collaboration
among the stakeholders and the specific methods and processes by which
the progress of its program will be reviewed and assessed.
Changes: None.
General Program Requirements--Common Features
Comment: Two commenters noted that, to allow individuals with
disabilities to fully participate in School-to-Work Opportunities
programs, the wording on outcomes must be revised to add, after ``a
high school diploma,'' the phrase, ``or alternative diploma or
certificate, as appropriate.''
Discussion: The Secretaries seek to establish systems that will
result in the attainment of a high school diploma or its equivalent,
and a skill certificate, for all students. States have the flexibility
to provide support services to students who may require additional
resources to obtain the outcomes sought to be achieved under the
program. However, as has been discussed above, the Secretaries do not
intend to discourage the participation of students with disabilities in
State School-to-Work Opportunities programs. Indeed, the School-to-Work
Opportunities initiative is intended to serve all students.
Accordingly, the Secretaries include within the term ``equivalent,''
which has been added to the definition of ``career major,''
certificates which States may choose to provide to students with
disabilities. These are considered to be equivalent to high school
diplomas.
Changes: Paragraph (b)(1) of the ``General Program Components''
section of the priority has been revised to indicate that the high
school diploma requirement may be satisfied when a student is awarded
the ``equivalent'' of a high school diploma, as determined under
standards by the State.
Program Components--General
Comment: One commenter considered the three program components
contained in the October 14, 1993 notice to be inadequate and suggested
that a section for support activities like counseling, child care, and
transportation, be added. The commenter felt that without these support
activities, programs would not attract and hold students who were drop-
outs, young parents, or disadvantaged, and whose past lack of success
had been due to the unavailability of such services.
Discussion: The program components required in the notice define
the core elements of a School-to-Work Opportunities program. The
Secretaries recognize that other support services may be necessary to
help students fully participate in the program, particularly in the
case of disadvantaged or disabled students, and in the case of
dropouts. The Secretaries do not, however, wish to render such
additional services mandatory in all cases. Moreover, under the notice,
States are already required to ensure opportunities for ``low-achieving
students, students with disabilities, and former students who have
dropped out of school to participate in School-to-Work Opportunities
programs.'' This will mean in some cases, providing support services.
Also, it is important to note that funds under this competition may be
used for support services. In addition, under the priority, States are
required to describe how their School-to-Work Opportunities systems
will coordinate the use of education and training funds from State and
private sources with funds available from related Federal programs.
(See paragraph (b)(4) of the priority.)
Changes: None.
Program Components--Work-Based Learning Component
Comment: One commenter recommended that the reference to
``instruction in a variety of elements of an industry'' in the work-
based learning section of program components, be revised to read:
``instruction in all aspects of an industry.'' The commenter further
recommended that the revised terminology be added to the requirement
for school-based learning.
Discussion: The Secretaries agree with the commenter that the
reference to instruction in a variety of elements of an industry should
not be a reference that is limited to the work-based component of the
program. Further, as previously discussed, there has been a change from
use of the term ``Elements of the industry'' in the October 14, 1993
notice, to use of the term ``All aspects of the industry.''
Change: The reference to ``Broad instruction in a variety of
elements of an industry'' has been deleted from the work-based learning
component of the ``General Program Requirements'' section. Paragraph
(a)(1) of the basic components section has been revised to provide that
one of the bases of a School-to-Work Opportunities system is the
integration of work-based learning and school-based learning ``that
provides participating students, to the extent practicable, with broad
instruction in all aspects of the industry the students are preparing
to enter.''
Comment: Several commenters felt that businesses may experience
difficulty in providing students with paid work experience,
particularly special needs students. One commenter stated that the
proposed requirements for work-based learning ignore the basic reality
that only a small minority of firms now provide significant training to
their own line workers below the management level--let alone to
``marginal'' high school youth. This commenter believed that the
requirements for work-based learning should be expanded to include
school-based work placements such as student-run enterprises and
school-sponsored community service programs, provided they are of
sufficient quality and intensity to otherwise meet the quality
requirements of the initiative.
Discussion: The Secretaries believe that paid work experience is an
important component of work-based learning in school-to-work programs.
Experts consulted in the development of this priority and in the
development of the proposed School-to-Work Opportunities legislation
strongly believe that jobs with pay increase employment experience for
youth, as well as increasing the value and importance of the youth to
the employer. Studies confirm these beliefs. Employers have continually
pointed out that paying wages is not the primary consideration in their
decision of whether or not to participate in school-to-work programs.
Small and medium sized businesses have a special incentive since these
have been found to be the most significant sources of employment for
youth. At the same time, however, the Secretaries agree that it is
important for partnerships to have as much flexibility as possible in
developing school-to-work programs, including having input on how the
paid work experience is constructed. For that reason, the priority
provides substantial flexibility. The priority does not require a
minimum amount of paid work experience nor does it specify at which
point in a program the paid work experience must occur. School-based
enterprises can provide the contexts in which the paid work experience
requirement could be met. In addition, other non-paid work experience,
such as job shadowing or on-the-job training for academic credit, are
not precluded by this priority, as complements to the paid work
experience component.
Changes: None.
Comment: One commenter believed that the October 14, 1993 notice
provides no real incentive for employers, particularly small
businesses, to spend their limited funds on hiring students. This
commenter would have the Secretaries include at least a sentence
describing the potential use of Targeted Jobs Tax Credits, to remind
grantees that they can make use of an existing incentive in their
implementation of their School-to-Work programs.
Discussion: The Secretaries agree with the commenter that there are
many existing vehicles, such as Targeted Jobs Tax Credits, of which
employers can avail themselves in the context of their involvement as
partners in their States' School-to-Work Opportunities programs. In the
course of providing technical assistance to the various States
receiving funding under this competition, the Secretaries plan to
inform States of any additional Federal resources, programs, or
initiatives that may assist States, partnerships, and members of
partnerships, in meeting the goals of the initiative and in
implementing their State School-to-Work Opportunities plans.
Importantly, there may be instances where it will be possible to use
Job Training Partnership Act funds to pay for work-based activities for
economically disadvantaged students. Funds awarded under this
competition may be used by employers to cover costs associated with the
work-based learning component of the program--for example, the training
of mentors. In addition, States may develop their own package of State
incentives to make participation more feasible or attractive for
employers.
Finally, the Secretaries strongly believe that the connecting
activities authority will provide significant support to participating
employers and to education institutions.
Changes: None.
Comment: One commenter believed that the notice should permit
students to receive some of their school-based instruction in the
workplace, regardless of whether the learning experience is paid or
unpaid.
Discussion: Under the School-to-Work Opportunities program,
students receive academic instruction from teachers at the school
setting, while receiving hands-on, work experience, including paid work
experience, from workplace mentors at the job site. The School-to-Work
Opportunities initiative is intended to break down barriers between
school and work and to provide States and local partnerships with
flexibility to design programs that contain the basic program
components within the local context. Assuming that requirements of the
three core components are otherwise satisfied, some degree of overlap
between the work-based and the school-based learning components, would
not necessarily be impermissible, and may, at times, be appropriate.
Changes: None.
Comment: One commenter noted that, to serve students with
disabilities, including those with severe disabilities, the Secretaries
should add, after ``paid work experience,'' the phrase, ``including
supported employment.''
Discussion: See discussion regarding paid work experience and the
flexibility surrounding it as well as previous discussions regarding
the requirement to ensure opportunities for all students, including
disabled students. Also, as previously discussed, funds awarded under
this competition may be used to help employers provide necessary
support to students, including disabled students.
Changes: None.
Comment: One commenter felt that States should be required to show
a broad and industry-wide commitment from employers to ensure that
students get the necessary industry-wide exposure.
Discussion: The Secretaries agree with the commenter that a
demonstration of industry-wide commitment to the School-to-Work
Opportunities program by any participating State is important toward
ensuring that employers are seriously committed to their State's
program and that all students are provided with adequate industry-wide
exposure. Conversely, employer involvement is important in ensuring
that School-to-Work Opportunity programs are responsive to business
needs. However, under the ``Comprehensive Statewide System'' selection
criterion and the ``Collaboration and Involvement of Key Partners''
selection criterion, the notice already addresses the commenter's
concerns. Under these criteria, States must demonstrate and describe
the commitment of employers and of State agency officials responsible
for job training and employment.
Changes: None.
Comment: One commenter noted that current co-op initiatives in
community colleges should be recognized and promoted in the notice. The
commenter believes that these initiatives have the established
infrastructure to implement school-to-work initiatives, including
networks of co-op administrators, job developers, faculty coordinators,
career counselors, and employer site supervisors. The commenter stated
that community colleges are positioned to link co-op programs between
secondary and postsecondary institutions and to improve their quality.
Discussion: The Secretaries agree with the commenter that community
colleges and programs sponsored by community colleges can make a
significant contribution to statewide school-to-work initiatives and
systems. In applying under this competition, States are to ``describe
the procedure for obtaining the active and continued involvement in the
statewide School-to-Work Opportunities system of employers and other
interested parties such as * * * postsecondary educational institutions
* * *.'' As the commenter notes, it is very possible that a co-op
program could be included as part of a School-to-Work Opportunity
system, so long as it meets the basic program requirements. The
Secretaries would expect States to discuss in their plans how they will
build on, modify, and enrich the efforts of community colleges to
develop comprehensive School-to-Work Opportunities systems that meet
the requirements of this priority.
Changes: None.
General Program Requirements--School-based Learning Component
Comment: One commenter stated that School-to-Work Opportunities
systems will never achieve their intended goal of creating high-quality
opportunities for all American youth unless programs contain: (1)
``Enabling tools'' to provide students and parents with the
information, assistance, capacity, and (2) safeguards necessary to
obtain the opportunities promised by the School-to-Work Opportunities
program. The commenter believed that it was necessary to provide
parents with: (a) An unambiguous statement targeted to all youth of the
opportunities provided by the program; (b) the information, assistance,
and authority for targeted youth and their parents to obtain access to
program opportunities, participate in shaping programs, and remedy the
problems that will inevitably occur; (c) systems for ensuring that
information about these program opportunities and involvement in
shaping the programs extends beyond the school district central offices
to the teachers; and (d) a statement of responsibilities for both
technical assistance and overseeing local implementation.
Discussion: The Secretaries agree that providing program
information to both parents and students, is essential to a student's
successful participation in, and completion of, a School-to-Work
Opportunities program. For that reason, they have added under
``examples of statewide activities,'' the clause ``working with
localities to develop strategies to recruit and retain all students in
programs, including those from a broad range of backgrounds and
circumstances,'' and, as an example of activities for local
partnerships, they have added the clause ``conducting outreach to all
students in a manner that most appropriately meets the needs of their
communities.'' Also, under paragraph (b)(3) of the priority, States are
required to describe their procedure for obtaining the continued
involvement of ``employers and other interested parties, such as * * *
students, parents * * *.'' Moreover, under the Student Participation
selection criterion, the Secretaries will evaluate whether each State
has proposed realistic strategies and programs to ensure that all
students have the opportunity to participate in the State's School-to-
Work Opportunities program. The Secretaries expect that a part of each
State's strategy for ensuring participation would be providing
information to all students about opportunities that are available to
them within the program. However, beyond these provisions, the
Secretaries are opposed to imposing further requirements upon States
governing the formulation and nature of the program information
disseminated.
Changes: The section on ``Examples of Statewide Activities'' has
been revised to include ``working with localities to develop strategies
to recruit and retain all students in programs including those from a
broad range of backgrounds and circumstances.'' As an example of
``Activities for Local Partnerships'' the following has been added:
``Conducting outreach to all students in a manner that most
appropriately meets their needs and the needs of their communities.''
Comment: One commenter observed that the academic outcomes expected
from school-based learning should qualify students to enter and succeed
in four-year postsecondary institutions upon graduation from high
school. This commenter saw a significant possibility that students who
enter a School-to-Work Opportunities program will face barriers to the
full range of postsecondary institutions, feeding parents' and
educators' tracking concerns. The commenter also believed that the
imperative for students to meet entrance requirements for four-year
institutions is made more critical by the early age at which youth will
be encouraged to select a ``career major.''
Discussion: The School-to-Work Opportunities initiative is not
limited to non-college-bound students. Rather, it is intended for all
students. The definition of the term ``All students'' refers to
students from a broad range of backgrounds and circumstances
``including * * * academically talented students.'' The notice states
that career majors would typically include two years of secondary
schools and one or two years of postsecondary education. As a result of
their participation in a School-to-Work Opportunities program, students
who are completing their first or second years at the postsecondary
level would be encouraged to consider different options in employment
and education, including enrollment in a four-year degree granting
college or university. In addition, since students in School-to-Work
Opportunities programs will be held to high academic standards,
including, where applicable, those developed under Goals 2000, the
Secretaries expect that these high standards will ensure that students
who have participated in their State's School-to-Work Opportunities
program are academically prepared for enrollment in four-year
postsecondary institutions. However, in response to this comment as
well as other related comments, the definition of ``career major'' has
been revised to include admission to a degree-granting college or
university as a possible outcome.
Changes: The definition of ``Career major'' has been revised to
include admission to a degree-granting college or university as a
possible outcome for participating students.
Comments: Two commenters stated that the proposed school-based
learning component is inadequate with regard to the degree of
participation that it requires from businesses and industries in such
areas as planning, curriculum and program development, instruction,
evaluation, and job placement. The commenters felt that the notice
fails to take sufficient advantage of many effective ways in which
business can be a partner with education throughout the entire
instructional process prior to actual paid job placement.
Discussion: The Secretaries strongly concur with the commenters
that the active and continued involvement of business and industry is
essential to the effective integration of school-based and work-based
learning. Under this competition, business and industry involvement is
a requirement, as provided for in paragraph (b)(3) of the priority
contained in this notice. Plans will be reviewed for evidence of such
involvement, as provided for in paragraph (b)(2) of the selection
criteria, ``Collaboration and Involvement of Key Partners--Involvement
by key parties.'' Moreover, the School-to-Work Opportunities program
does not limit the involvement of business and industry nor limit their
roles in the collaborative partnerships. Indeed, business will
necessarily play a key role in the design as well as the implementation
of each State's School-to-Work Opportunities program.
Changes: None.
Comment: One commenter believed that, while still in school,
students should be linked with the workplace for mentoring, job-
shadowing, and other context-based experiences that can contribute to
increased program completion and employment. Another commenter believed
that businesses should provide significant input to the design of
curriculum, provide mentors, pay students, develop skills standards,
and employ youth. This commenter advocated the involvement of employers
who currently participate in work and learning programs, rather than
merely involving industry leaders.
Discussion: The Secretaries strongly concur with both of these
commenters but believe that the notice currently addresses their
concerns.
Changes: None.
Comment: One commenter was of the opinion that there is virtually
no capacity in schools or anywhere else to counsel students on career
majors and suggested that this area of the initiative be considered
further. Another commenter noted that the school-based learning
component does not specify when career counseling should begin. A third
commenter suggested that, since the first bullet under ``school-based
learning'' suggests that career majors may be ``reconsidered,'' a
second bullet should be added immediately under it, to read: ``School-
based learning that includes the integration of occupational
information and career development assistance into academic instruction
and the availability to students of direct access to that occupational
information and those career development assistance tools that relate
occupational choice to educational attainment.'' The commenter believed
that, without this additional requirement, the choices made by students
may not be realistic or appropriate.
Discussion: The Secretaries agree that, in many cases, students do
not receive the guidance and counseling needed to make important
decisions related to education and training leading to meaningful
employment. It is for this reason that career exploration and
counseling is required as an important activity in the school-based
learning component of the notice. States seeking to receive a grant
under this competition must demonstrate that the school-based learning
component of their School-to-Work Opportunities systems will include
career exploration and counseling. In addition, however, in response to
the commenter's concerns, the Secretaries have revised the School-based
Learning component to require, among other stated elements, ``career
awareness and exploration and counseling (beginning at the earliest
possible age)'' in order to help those students who may be interested,
to identify and select or reconsider, their interests, goals, and
career majors, ``including those options that may not be traditional
for their gender, race or ethnicity.'' By this change, the Secretaries
wish to emphasize the importance of career awareness and exploration at
an early age. The determination of the actual age or grade level at
which this activity should begin, has been left to the States.
Changes: The School-based Learning component has been revised to
require, among other stated elements, ``career awareness and
exploration and counseling (beginning at the earliest possible age)''
in order to help those students who may be interested, to identify and
select or reconsider, their interests, goals, and career majors,
``including those options that may not be traditional for their gender,
race, or ethnicity.''
General Program Requirements--Connecting Activities
Comment: One commenter believed that the description of information
collection and analysis in the connecting activities component of the
``General Program Requirements'' of the priority is too general to
provide useful information. The commenter believed that the information
should include annual participation and post-program outcomes, and that
the data should be ``disaggregated'' by gender, race, ethnicity, socio-
economic background, limited-English proficiency, and disability, so
that any lack of participation or achievement by one group would not be
masked by the success of the program for the general population.
Discussion: The Secretaries agree with the commenters that
disaggregated data is likely to be important for determinations of the
success of the program for all groups. They would expect that the
information collected and analysis provided under the connecting
activities component to describe student participation in the program.
This may include information on gender, race, ethnicity, socio-economic
background, limited-English proficiency, and disability.
Changes: A change has been made to the ``General Program
Requirements Connecting Activities'' section of notice so that it is
specified that among the information that may be collected is
information on gender, race, ethnicity, socio-economic background,
limited-English proficiency, and disability.
Comment: One commenter requested that the Secretaries add the
following additional requirement to the list of connecting activities
in the priority: ``Providing job coaching services to youth with
disabilities within a supported employment model.'' The commenter
believed that job coaches could help students acquire job skills and
could help employers achieve the workplace accommodations that may be
necessary to job success.
Discussion: As is provided for in the school-based and work-based
learning components respectively, career exploration and counseling, as
well as workplace mentoring, must be provided to all students. In
addition, the notice requires States to describe in their applications
how they will ensure opportunities for all students, including students
with disabilities, to participate in School-to-Work Opportunities
programs. While the Secretaries believe that funds awarded under this
competition may be expended to cover the costs of what the commenter
has referred to as job coaching for disabled students within a
supported employment model, States may also seek to utilize funds
available from other sources to meet what may be the special needs of
disabled students participating in their School-to-Work Opportunities
programs. Indeed, under paragraph (b)(4) of the priority, States are
specifically required to describe how their School-to-Work
Opportunities systems will coordinate the use of education and training
funds from State and private sources with related Federal program
funds.
Changes: None.
Examples of Statewide Activities
Comment: One commenter requested the inclusion of ``related
services personnel'' among those individuals for whom training could be
provided by a grantee receiving funds under this competition. The
commenter felt that related services personnel would be critical to the
success of students with disabilities in School-to-Work Opportunities
programs and that these individuals should be trained along with the
teachers and other professionals named in paragraph (c) under
``Examples of Statewide Activities.''
Discussion: Under the section of the notice entitled ``Examples of
Statewide Activities'' there is a list which is meant only to be
illustrative and to provide examples of some of the grantee
expenditures that would be allowable under this program. The
Secretaries agree that the costs of training related services personnel
is sufficiently important to be added to the list as an allowable
expenditure under this program.
Changes: Reference to ``related services personnel'' has been added
to the list of those individuals for whom training could be provided by
a grantee under this program.
Comment: One commenter recommended that examples should be added to
the list of statewide activities to focus on the needs of disadvantaged
youth and poor communities. The commenter proposed adding, as an
example of allowable statewide activities, stimulating the development
of partnerships in poor communities, and providing training and
dissemination of curricula to local partnerships to more effectively
respond to the needs of disadvantaged youth.
Discussion: The Secretaries agree with the commenter that the
examples of statewide activities should include activities aimed at
addressing the particular needs of disadvantaged youth and poor
communities. Accordingly, paragraph (b) of the examples has been
revised to include stimulating the development of partnerships in poor
communities. The Secretaries note that the statewide activities as
proposed include the training and curricula dissemination activities
cited by the commenter, for teachers, employers, workplace mentors, and
others, at the local level. However, the Secretaries believe that an
additional activity should be added, to clarify that States may assist
localities in formulating strategies to recruit and retain all students
including the poor and disadvantaged. These strategies may include the
training and curricula dissemination activities described in paragraphs
(c) and (e) of the examples.
Changes: Paragraph (b) under ``Examples of Statewide Activities''
has been revised to include the clause: ``Stimulating the development
of partnerships in poor communities'' as an outreach activity to
promote and support collaboration in School-to-Work Opportunities
programs. In addition, a new paragraph (h) has been added to provide
that States may work ``with localities to develop strategies to recruit
and retain all students in School-To-Work Opportunities programs,
including those from a broad range of backgrounds and circumstances.''
Allocation of Funds to Local Partnerships
Comment: One commenter felt that the Secretaries should require
local partnerships to describe how they will train counselors and other
personnel to provide minority, female, disabled, and limited-English
proficient youth with access to high-skill, high-wage, non-traditional
careers. The commenter believed that such a requirement should be
included in this section on ``Allocation of Funds to Local
Partnerships'' and that it should be given as an example in the
succeeding section, ``Examples of Activities for Local Partnerships.''
Discussion: The Secretaries agree that training is an important
activity, and have included ``training for teachers, employers,
workplace mentors, counselors, and others,'' as examples of State
activities and ``providing training to work-based and school-based
staff on new curricula, student assessments, student guidance, and
feedback to the school regarding student performance,'' as examples of
local partnership activities. Also, one of the requirements under
school-based learning is ``career awareness and career exploration and
counseling in order to help students who may be interested to identify
and select or reconsider their interests, goals, and career majors.''
The Secretaries do not wish to mandate to local partnerships who should
be trained or how the training should be accomplished. Rather, the
Secretaries think it is preferable for local partnerships to make those
determinations in ways that best serve the programs which they are
implementing and the students participating in those programs.
Changes: None.
Examples of Activities for Local Partnerships
Comment: Two commenters had suggestions regarding the ``Examples of
Activities for Local Partnerships'' provided in the notice. One
commenter believed that paragraph (f) (redesignated as paragraph (g))
should be changed to specifically allow students with disabilities to
participate in graduation assistance programs to help them graduate
from high school, continue their education or training, and to find
jobs as well as advance in them. The second commenter requested the
Secretaries to add the word, ``all,'' before ``at risk and low-
achieving students'' in paragraph (f) (redesignated as paragraph (g)).
The commenter felt that this change was necessary to ensure that all
categories of students listed in the definition of ``All students''
would be served. The commenter also suggested changing the last phrase
in paragraph (f) of the October 14, 1993 notice, to read, ``* * * and
finding, maintaining or advancing in jobs,'' to emphasize that
maintaining a job is equally as important as finding one.
Discussion: The Secretaries agree with commenters that graduation
assistance programs should be geared to serving all students, as
defined in the notice, and that the activity described in redesignated
paragraph (g) should clearly refer to disabled students as well as to
at-risk and low-achieving students. The Secretaries also believe that
``maintaining a job'' is consistent with the desired outcomes of the
School-to-Work Opportunities initiative and of this competition, and
have added the word, ``maintaining'' to redesignated paragraph (g) of
the ``Examples of Activities for Local Partnerships.'' The commenter on
the availability of occupational information and career development
assistance has suggested two, among what may be many, additional
worthwhile activities that might be carried out under a local
partnership. The Secretaries, because this section is purely
illustrative and in the interest of brevity, have elected not to
include them in the final priority. Although the Secretaries find
commendable, the suggestion to require that all at-risk and low-
achieving students be served in a graduation assistance program, the
Secretaries fully understand the difference between ``equal access to
opportunity'' and a ``guarantee,'' and, because of the limited
resources available, have elected to have local partnerships provide
``opportunity for all students'' in preference to a guarantee.
Changes: The notice has been modified by adding the word,
``disabled'' to redesignated paragraph (g) in the section on ``Examples
of Activities for Local Partnerships,'' so that it now reads: ``* * * a
graduation assistance program to assist at-risk, disabled, and low-
achieving students, in graduating from high school. * * *.'' In
addition, the Secretaries have modified this same paragraph by adding
the word ``maintaining'' to the end of the paragraph. Accordingly, the
notice now provides, specifically, that funds awarded by States to
local partnerships under this competition may be utilized for the
purpose of assisting at-risk, disabled, and low-achieving students in
graduating from high school, enrolling in postsecondary education or
training, and finding, maintaining, or advancing in jobs.
Comment: One commenter, expressing concern with what he referred to
as decisionmakers' access to occupational information, suggested adding
two activities to the list of activities for local partnerships. The
commenter suggested revising paragraph (h) to specifically authorize
the creation of after school, School-to-Work career centers, where
students and parents could seek occupational and career information,
carry out career exploration, seek guidance regarding career choices or
the design of an educational program, or evaluate the educational
preparation that students have received to date. The commenter also
suggested adding a paragraph to authorize the publication of career
information for use by parents and students, in cooperation with the
State Occupational Information Coordinating Committee.
Discussion: The issue raised by the commenter is discussed earlier
in the context of the School-to-Work Opportunities program's school-
based learning component. In this context also, in suggesting that
funds awarded under this competition be utilized for preparing and
making available important program information for parents and students
in after school centers or in publication, the commenter has suggested
an activity that the Secretaries would consider to be an allowable
activity for local partnerships.
Changes: None.
Examples of Activities for Local Partnerships--Youth
Comment: One commenter felt that the notice's references to youth
for example, in paragraph (h) of Examples of Activities for Local
Partnerships in the context of providing opportunities for dropout
students were unclear. The commenter suggested defining the term
``youth'' so as to include, at a minimum, young persons up to, and
including, age 25, to allow for the inclusion of young men and women
who have dropped out, become parents, and face multiple obstacles to
achieving a self-sufficient wage. Another commenter believed that
defining the term ``youth'' to include students in the elementary
grades would enhance the opportunities of children to develop early
career awareness, thereby increasing School-to-Work Opportunities
program participation rates in the high schools.
Discussion: Since the focus of the School-to-Work initiative and of
this notice is on system building and institutional change, there are
no detailed provisions for individual eligibility. The Secretaries
believe that States should have the flexibility to determine the age
range of the student population for their School-to-Work Opportunities
programs. However, States are expected to develop systems that
coordinate other education and training programs funded from sources
that do set parameters for the youth to be served. For example, the Job
Training Partnership Act limits the age of the youth to be served to 16
through 21 years of age. In addition, the required school-based
learning component must include career awareness and career exploration
and counseling. These activities may be carried out in the elementary
and middle school years to better prepare students for School-to-Work
Opportunities programs, as States and localities retain the flexibility
to begin career awareness and counseling programs at as early a grade
level as appears to be appropriate and useful.
Changes: None.
Comment: One commenter felt that a student's eligibility to
participate in a School-to-Work Opportunities program should not be
determined by student population based on age, such as age 16 through
21, but rather should be geared to grade level. The commenter believed
that a student's eligibility to participate in School-to-Work
Opportunities program should begin in ninth grade, since, in this way,
all students would have an equal opportunity to qualify for the
program.
Discussion: As is discussed above, the Secretaries believe that
States should retain the flexibility to design School-to-Work
Opportunities systems, within the parameters of the program as
contained in this notice, that best meet the needs of their students.
Changes: None.
Safeguards
Comment: One commenter requested that the Secretaries establish
additional safeguards, beyond those provided for in the notice, so as
to ensure student access, services, information, and assistance to
students and parents. Another commenter suggested adding a new
safeguard to provide that nothing in this notice should be construed as
modifying or affecting the Fair Labor Standards Act.
Discussion: Regarding the applicability of the Fair Labor Standards
Act, the Secretaries note that, as a matter of law, this notice does
not and cannot in any way modify or affect either the Fair Labor
Standards Act or its applicability. However, the Secretaries agree with
the commenter's suggestion that a reference to applicable fair labor
standards would be helpful in the context of the ``Safeguards'' section
of the notice. Regarding the commenter's suggestion that additional
safeguards be added to the list, the Secretaries do not believe that
this is necessary, since relevant Federal and State law will continue
to apply to this program, regardless of whether these are specifically
mentioned or listed in the notice.
Changes: The notice has been modified to include the word ``labor''
in paragraph (d) of the ``Safeguards'' section of the notice. Paragraph
(d) now reads: ``Students shall be provided with adequate and safe
equipment and a safe and healthful workplace in conformity with all
health, safety, and labor standards of Federal, State, and local law.''
Selection Criteria--Comprehensive Statewide System
Comment: In making choices among standards and assessments for
occupational skills, one commenter suggested that States be required to
consider whether the standards and assessments chosen reflect the needs
of high-performance workplaces, whether they are benchmarked to the
highest international standards, and whether they reflect requirements
of clusters of occupations requiring similar skills, rather than
individual jobs or occupations. The commenter suggested that among the
needs of high performance work organizations are the acquisition of
skills required to be an effective member of a work group, the capacity
to learn new skills quickly, broad analytical and systems thinking
skills, and specific skill sets that facilitate high mobility among a
wide variety of related jobs and occupations within an industry and
among different industries.
Discussion: The Secretaries agree that State skill standards and
methods of skill assessment must be benchmarked to high quality
standards in order to ensure, to the extent possible, that students
receiving portable skill certificates under the School-to-Work
Opportunities program will have the opportunity to enter high-skill,
high-wage, employment. Therefore, the clause ``benchmarked to high
quality standards'' is added to the definition of the term ``Skill
certificate.'' Similarly, a question has been added to the
``Comprehensive Statewide Systems'' selection criterion requiring
States to indicate in their applications whether their processes for
assessing skills reflect the needs of high performance workplaces as
well as meeting the requirements of broad clusters of related
occupations and industries, rather than those of individual jobs or
occupations. The Secretaries generally agree with the commenter that,
in making their choices among standards and assessments for
occupational skills, States should choose standards and assessments
that build upon available standards and assessments; incorporate those
skills that are necessary for employees to participate as active
members of a work group and serve as team leaders; utilize high
standards in an industry, occupation or profession; include measures of
broad analytical and thinking skills; and reflect the requirements of
clusters of occupations, requiring similar skills, rather than
narrowly-defined individual jobs or occupations.
Changes: In response to the commenter, the definition of the term
``Skill certificate'' has been revised to require that skills be
benchmarked to high quality standards. In addition, the following
question has been added to the ``Comprehensive Statewide System''
criterion: ``Does the State's process for assessing skills reflect the
needs of high performance workplaces as well as meet the requirements
of broad clusters of related occupations and industries, rather than
those of individual jobs or occupations?''
Comment: One commenter suggested that the selection criterion
``Comprehensive Statewide System'' include a question asking applicants
to describe how their School-to-Work Opportunities system is a part of
school-wide restructuring that provides every student in each school
with experimental learning programs--hands-on learning, students'
demonstration of skills through projects, mentoring and coaching
relationships, and increased student self-esteem and motivation that
are linked with academic education.
Discussion: School-to-Work Opportunities systems under the priority
established in this notice must integrate work-based learning and
school-based learning. School-to-Work Opportunities programs must
incorporate a planned program of job training and experiences, paid
work experience, workplace mentoring, and a program of study designed
to meet the same challenging academic standards developed for all
students. The criterion ``Comprehensive Statewide System'' is intended
to encourage applicants to describe how their proposed School-to-Work
Opportunities systems will produce systemic statewide change that will
have a substantial beneficial impact on the preparation of youth for
either a first job or further training or education.
This criterion also encourages States to describe State and local
performance standards that lead to statewide systemic reform of
secondary education. The ``Local Programs'' criterion is intended to
elicit a detailed description of the School-to-Work Opportunities
system to be implemented at the local level. The Secretaries expect
that, combined, these criteria will result in applicants submitting
descriptions of State plans that provide for fundamental statewide
restructuring of existing education and training programs.
Changes: None.
Comment: One commenter who believed that community-based
organizations and the human services sectors are currently under-
utilized, suggested that a question be added under the selection
criterion ``Comprehensive Statewide System'' to read: ``Does the plan
describe methods to ensure high school completion by participants such
as graduation assistance programs targeting low-achieving and at-risk
youth or offering human services in coordination with education and job
training?'' One commenter was concerned that occupational and career
information and career guidance and counseling be provided and
suggested adding a question to read: ``Has the State incorporated into
the Statewide plan provisions for the presentation of occupational and
career information and career development assistance to all students in
all parts of the State?''
Discussion: The Secretaries agree with the commenter that in
response to this notice applicants should describe the methods that
they have selected to ensure high school completion. The criterion
``Student Participation'', therefore, focuses on providing ``all
students'', including low-achieving students, the opportunity to
participate in School-to-Work Opportunities programs. The ``Local
Programs'' criterion emphasizes that plans must include programs that
result in the award of high school diplomas, as is otherwise required
in the notice. With respect to the commenter's suggestion that
statewide plans provide for the presentation of occupational and career
information and career development assistance, one of the ``General
Program Requirements'' already contained in the priority, is that the
school-based learning component of any School-to-Work program include
career exploration and counseling.
Changes: None.
Selection Criteria--Collaboration and Involvement of Key Partners
Comment: One commenter suggested adding State officials responsible
for special education, vocational rehabilitation, and other transition
services, to the list of State level officials with whom applicants are
encouraged to collaborate in implementing statewide School-to-Work
Opportunities systems. Other commenters suggested adding a variety of
entities to the list of key parties to be involved in the
implementation of States' School-to-Work Opportunities systems.
Specifically, commenters suggested adding vocational and comprehensive
high schools, local vocational education agencies, private industry
councils established under the Job Training Partnership Act (JTPA),
related services personnel, State Occupational Information Coordinating
Committees and other occupational information providers, human services
agencies, JTPA operators and educational programs serving farmworkers.
One commenter was of the opinion that the involvement of other parties
cannot serve as a substitute for the involvement of students, parents,
teachers, and area residents in State and local decision-making. The
commenter also felt that the statewide system should include as many as
possible of the interested parties listed under the criterion
``Involvement by Key Parties.''
Discussion: The lists of entities under paragraphs (b) (1) and (2)
of the selection criterion ``Collaboration and Involvement of Key
Partners'' are not intended to be exhaustive, but, rather, are intended
to provide examples of entities that should be involved in developing
and implementing a successful School-to-Work Opportunities system. It
is likely that the other entities suggested by the commenters also
would contribute to the success of State and local School-to-Work
Opportunities activities and it would be appropriate for State and
local agencies to seek their involvement. In accordance with these
criteria, as well as with paragraphs (b)(2) and (b)(3) of the priority,
the Secretaries strongly encourage the involvement of all groups and
entities that can perform useful and productive functions in the
implementation of State School-to-Work Opportunities programs.
Changes: None.
Selection Criteria--Student Participation
Comment: One commenter felt that under the ``Student
Participation'' selection criterion insufficient attention is accorded
to the adequacy of plans to reach and serve out-of-school youth
effectively and suggested adding a specific question to address this
perceived deficiency. Another commenter said that the description of
``all students'' in the selection criteria is inconsistent with the
definition of the term in the notice's ``Definitions'' section, which
includes students with limited-English proficiency. The commenter would
have this population added to the selection criterion.
Discussion: The priority established in this notice requires State
plans to include realistic strategies and programs to ensure that all
students have the opportunity to participate in School-to-Work
Opportunities systems. With regard to the comment on service to out-of-
school youth, the Secretaries note that the definition of the term
``All students'' has been modified to include students who have dropped
out of school. The Secretaries recognize that the definition of ``All
students'' includes individuals with limited-English proficiency and
agree that, for consistency, the reference to students with limited-
English proficiency also should be included in this criterion.
Changes: The ``Student Participation'' criterion has been modified
to include specific reference to students with limited-English
proficiency.
Comment: One commenter was concerned that the children of migrant
and seasonal farmworkers are often overlooked by States and suggested
that the Secretaries add ``migrant and seasonal farmworker children''
among those explicitly intended to be served under the program. The
commenter also suggested that States be encouraged to provide early
intervention for youth, particularly youth at risk of dropping out of
school at an early age.
Discussion: As written, the ``Student Participation'' criterion
calls for realistic strategies and programs to included all students.
In States with migrant workers and seasonal farmworkers, this would
include the children of those individuals. The Secretaries expect those
students to be provided with the opportunity to participate in School-
to-Work Opportunities programs. Additionally, the Secretaries strongly
encourage States to provide early intervention for youth, particularly
youth at risk of dropping out of school at an early age.
Change: None.
Selection Criteria--Local Programs
Comment: One commenter suggested that the ``Local programs''
selection criterion be modified to permit supported employment as a
part of work-based learning. The commenter was also concerned about the
participation of special education students and suggested that the
phrase ``or alternative certificate'' be added after ``award of a high
school diploma.'' The commenter also felt that the phrase ``including
those funded under JTPA, IDEA, Carl D. Perkins Vocational and Applied
Technology Education Act (Perkins Act), the Rehabilitation Act, and
JOBS'' should be added following the question ``Have promising existing
programs been considered for adaptation?''
Discussion: With regard to the suggestion that the ``Local
programs'' selection criterion be modified to permit supported
employment as a part of work-based learning, such a change would make
the selection criterion inconsistent with the priority, which includes
a safeguard prohibiting the use of funds awarded under this competition
for the payment of wages to students. The Secretaries encourage
grantees to use other Federal, State, local, public, and private
resources to provide supported employment, work study, and cooperative
education where these approaches facilitate work-based learning. With
regard to the comment suggesting that alternative certificates be
accepted in lieu of high school diplomas for disabled students, the
clause ``or its equivalent'' is added to this part of the notice to
provide for alternative certificates for disabled students. Finally,
while the Secretaries agree with the commenter that programs under the
JTPA, IDEA, Perkins Act, Rehabilitation Act, and JOBS have produced
practices that should be considered for adaptation, other Federal,
State, and local programs have also developed promising programs that
States and locals may wish to consider. The Secretaries encourage
States and localities to adapt all promising programs to their School-
to-Work Opportunities systems in a manner that best suits the systems
they plan to implement.
Changes: The clause ``or its equivalent'' has been added to the
definition of the term ``Career major,'' to the ``General Program
Requirements'' section of this notice, and to the ``Local Programs''
criterion, providing for alternative certificates for disabled
students.
Selection Criteria--Management Plan
Comment: One commenter felt that greater emphasis should be given
to States that present new or alternative methods of assessment for
their activities. This commenter also believed that priority should be
given to applicants that are able to demonstrate real innovation on the
part of their own staff as well as on the part of the stakeholders they
have brought together.
Discussion: The Secretaries agree with the commenter that special
consideration should be given to States that propose innovative
approaches and have added this factor to the decision-making process of
the Secretaries.
Changes: The notice has been modified so that the description of
the review process included under ``Selection Criteria for Evaluating
Applications'' has been revised to state that final funding decisions
made by the Secretaries will also include consideration of such factors
as replicability, sustainability, and innovation. In addition, the
``Management Plan'' criterion now asks the question ``Does the
management plan include a process for incorporating methods to improve
or redesign the implementation system based on program outcomes?''
Comment: One commenter was concerned about special education
students and expressed the belief that interagency data collection is
essential for monitoring the success of special education programs and
requested that the Secretaries add a question to read: ``Does the
State's management plan include a system for interagency data
collection?'' This commenter also requested the insertion of the word
``cross-trained'' into the question on key personnel so that it would
read ``Are key personnel under the plan cross-trained and qualified to
perform * * *.'' This commenter believed that key personnel should be
knowledgeable on both labor and educational issues.
Discussion: The Secretaries agree that the provision of
occupational and career development assistance as well as program
information, guidance, and counseling, are all important aspects of
School-to-Work Opportunities programs to be developed under the
priority. However, the Secretaries believe that the importance of these
is already provided for in the priority as written. While the
Secretaries agree with the commenter that it would be beneficial for
applicants to utilize key personnel who are knowledgeable of both the
labor and educational components, the Secretaries do not think it
advisable to prescribe the qualifications of key personnel. The
Secretaries prefer to leave those decisions to the States.
Changes: None.
Comment: One commenter was concerned about the sufficiency of
occupational and career information provided under School-to-Work
Opportunities programs and suggested adding two questions to the
``Management Plan'' criterion, to read: ``Does the State management
plan adequately address the timely provision of accurate occupational
and career information to school and program administrators, teachers
and counselors, students and parents throughout the State?'' and ``Does
the State management plan adequately address the need to provide career
development assistance, guidance and counseling to students and parents
in all parts of the State?''
Discussion: The Secretaries have concluded that, since the
implementation of School-to-Work Opportunities programs will be a joint
effort involving coordination among Federal, State, and local entities,
it is likely that effective methods to improve or redesign a project's
implementation will be shared among these.
Changes: None.
Selection Criteria--Distribution of Points
Comment: One commenter questioned the distribution of points among
the selection criteria and recommended that the points be redistributed
with 20 points for the ``Comprehensive Statewide System'' criterion, 17
points for the ``Collaboration and Involvement of Key Partners''
criterion, 17 points for the ``Resources'' criterion (particularly if
the disadvantaged are to meet the same goals as other students), 17
points for the ``Student Participation'' criterion, 17 points for the
``Local Programs'' criterion, and 12 points for the ``Management Plan''
criterion. Another commenter concerned with special education students
suggested that more points be awarded for the ``Local Programs''
selection criterion.
Discussion: The Secretaries have given much consideration to the
distribution of points among the selection criteria. They have
concluded that the distribution provided for in the notice results in
the most appropriate balance among the criteria.
Changes: None.
Selection Criteria--General
Comment: One commenter believed the notice must be strengthened to
ensure that all youth receive the assistance and services they need to
fully participate and succeed and processes are in place for
identifying and addressing disparities in participation and success.
The commenter recommended that the Secretaries add a selection factor
that reads: ``Are there adequate State and local provisions to ensure
equal access to all programs and program components; supplemental
services and accommodations necessary for various students to
participate and succeed; the collecting of disaggregated data on how
well different groups are being served; and the taking of effective
steps to remedy unequal participation or outcomes (based on data
concerning how groups need to be served)?''
Discussion: In reviewing applications under this competition, the
Secretaries will seek to determine the extent to which applications
propose realistic strategies and programs to ensure that ``all
students'' have an opportunity to participate in the State's School-to-
Work Opportunities programs. In order to succeed in a School-to-Work
Opportunities program, some students may need additional assistance. In
this regard, the selection criterion ``Student Participation'' will be
used to assess applicants' strategies for recognizing barriers to
participation and proposing effective ways of overcoming them. However,
the program funded under this competition does not purport to guarantee
access to every student.
Changes: None.
Comment: One commenter suggested that the selection criteria
consider the extent and quality of a State's implementation of key
Perkins Act provisions, including all aspects of the industry,
academic-vocational integration, full access, services and success for
individuals who are members of special populations, and effective
participatory planning with students, parents, teachers, and area
residents in terms of: (a) the extent of the State's current
implementation of those provisions, and (b) how they will be
coordinated with and incorporated into the comprehensive school-to-work
system. This commenter believed the individual States' track records in
implementing these Perkins Act provisions would be good indicators of
their capacities for commitments to high quality implementation of
School-to-Work Opportunities systems.
Discussion: Because the School-to-Work Opportunities system to be
developed and implemented under the priority will involve the
coordination of education and training resources of many different
Federal, State, and private sources, the Secretaries believe that a
State's track record in implementing Perkins Act provisions, while
important, is only one of many critical factors that serve as
indicators of commitment and ultimately contribute to a successful
School-to-Work Opportunities system. The Secretaries do not believe
that giving special emphasis to a State's implementation of provisions
under the Perkins Act fosters the intent that States develop
comprehensive School-to-Work Opportunities systems that incorporate the
best practices and programs regardless of funding source.
Changes: None.
[FR Doc. 94-2387 Filed 2-2-94; 8:45 am]
BILLING CODE 4000-01-P
