[Federal Register Volume 60, Number 96 (Thursday, May 18, 1995)]
[Notices]
[Pages 26812-26821]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-12332]
[[Page 26811]]
_______________________________________________________________________
Part VI
Department of Labor
_______________________________________________________________________
Employment and Training Administration
Department of Education
_______________________________________________________________________
Office of Vocational and Adult Education; School-to-Work Opportunities
Act; State Implementation Grants; Notice
Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 /
Notices
[[Page 26812]]
DEPARTMENT OF LABOR
Employment and Training Administration
DEPARTMENT OF EDUCATION
Office of Vocational and Adult Education; School-to-Work
Opportunities Act; State Implementation Grants
AGENCIES: Department of Labor and Department of Education.
ACTION: Notice Inviting Applications for New Awards for Fiscal Year
(FY) 1995 and Notice of final selection criteria and a definition of
administrative costs for School-to-Work Opportunities State
Implementation Grants (State Implementation Grants) to be made in
fiscal year 1995 and in succeeding years.
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SUMMARY: The Departments of Labor and Education jointly invite
applications for new awards in FY 1995. The Departments also announce
final selection criteria to be used in evaluating applications
submitted under the State Implementation Grants competition in FY 1995
and in succeeding years, authorized under section 212 of the School-to-
Work Opportunities Act of 1994 (the Act). State Implementation Grants
will enable States to implement their plans for statewide School-to-
Work Opportunities systems. Such systems will offer young Americans
access to programs designed to prepare them for a first job in high-
skill, high-wage careers, and for further education and training. The
Departments also announce a definition for the term ``administrative
costs'' that will apply to State Implementation Grants funded under the
Act.
DATES: The closing date for receipt of applications is June 19, 1995.
SUPPLEMENTARY INFORMATION:
Background
The Departments of Labor and Education are reserving funds
appropriated for FY 1995 under the Act (Pub. L. 103-329) for a
competition for State Implementation Grants authorized under section
212 of the Act.
This notice contains a definition of the term ``administrative
costs'' and the selection criteria that will be used in evaluating
applications submitted in response to this year's competition.
Invitation for Application for New Awards
Purpose of Program: These funds will serve as ``venture capital''
to allow States to build comprehensive School-to-Work Opportunities
systems which provide all youth with high-quality education that
integrates school-based learning, work-based learning and connecting
activities, prepares young Americans for success in high-skill, high-
wage careers, and increases their opportunities for further education
and training.
Eligible Applicants: All States that did not receive a State
Implementation Grant in FY 1994, the District of Columbia, and Puerto
Rico are eligible for Implementation Grants under this competition. In
accordance with the School-to-Work Opportunities Act, the Governor must
submit the application on behalf of the State.
Deadline for Transmittal of Applications: The closing date for
receipt of applications is June 19, 1995, at 2 p.m. (Eastern Time).
Telefacsimile (FAX) applications will not be honored.
Availability of Applications: Application packages will be mailed
directly to both the Governor and the State School-to-Work Development
Grant contact of each eligible applicant, as listed above. Applications
will be mailed to applicants, via overnight mail, within one day of the
publication of this notice in the Federal Register. Any other party
interested in receiving a copy of the application package should
contact: School-to-Work Office, 400 Virginia Avenue, S.W., Room 100-C,
Washington, D.C. 20024. Telephone: (202) 401-6222.
Available Funds: Approximately $86,000,000 (funding for the first
twelve months).
Estimated Range of Awards: The Departments expect the minimum award
to be approximately $1.5 million and the maximum award to be
approximately $20 million. The Departments wish to emphasize that, in
accordance with sections 212, 213, 214, and 216 of the Act, the actual
amount of each award made under this competition will depend on such
factors as the scope and quality of the State plan and application, the
number of projected participants in programs operating within each
State's School-to-Work Opportunities system, and the State's youth
population. Therefore, the Departments strongly encourage applicants to
consider these factors, the estimated average grant award amount, and
the amount of awards made to the first eight Implementation States in
deciding what funds to request. Applicants are discouraged from
requesting significantly more funds than States with similar numbers of
school-age youth received last year without a strong programmatic basis
for doing so. (Information on last year's awards is contained in the
application package.)
Estimated Average Size of Awards: $4.5 million.
Estimated Number of Awards: Up to 20.
Note: The Departments are not bound by any estimates in this
notice.
Project Period: Up to 5 years (5 twelve-month grant periods).
Applicable Regulations: 29 CFR Parts 33, 93, 95, 96, 97, 98. The
selection criteria and definition published in this notice, as well as
the instructions contained in the application package and the
eligibility and other requirements specified in the Act, apply to this
competition.
For Additional Information Contact: Ms. Laura Cesario, U.S.
Department of Labor, Employment and Training Administration, Division
of Acquisition and Assistance, 200 Constitution Avenue NW., Room S-
4203, Washington, D.C. 20210. Telephone: (202) 219-7300, extension 21
(this is not a toll-free number). 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.
Reference: SGA # DAA--007.
Implementation Grant Competition
Analysis of Comments and Changes
On March 10, 1995, the Departments of Labor and Education published
a notice of proposed selection criteria and a proposed definition of
the term ``administrative costs'' for this competition and competitions
in succeeding years in the Federal Register (60 FR 13312-13315). In
response to the invitation to comment, 55 parties submitted comments.
An analysis of the comments received in response to the publication of
that notice and of the changes made to the selection criteria and
definition since publication of the notice of proposed criteria and
proposed definition is published as an appendix to this notice.
School-to-Work Opportunities State Implementation Grants
Definition
All definitions in the Act apply to School-to-Work Opportunities
systems funded under this and future State Implementation Grant
competitions. Since the Act does not contain a definition of the term
``administrative costs'' as used in section 217 of the Act, the
Departments will apply the following definition to this and future
[[Page 26813]] competitions for State Implementation Grants:
The term ``administrative costs'' means the activities of a State
or local partnership that are necessary for the proper and efficient
performance of its duties under the School-to-Work Opportunities Act
and that are not directly related to the provision of services to
participants or otherwise allocable to the system's allowable
activities listed in section 215(b)(4) and section 215(c) of the Act.
Administrative costs may be either personnel costs or non-personnel
costs, and direct or indirect. Costs of administration shall include,
but not be limited, to:
A. Costs of salaries, wages, and related costs of the grantee's
staff engaged in:
Overall system management, system coordination, and
general administrative functions;
Preparing program plans, budgets, and schedules, as well
as applicable amendments;
Monitoring of local initiatives, pilot projects,
subrecipients, and related systems and processes;
Procurement activities, including the award of specific
subgrants, contracts, and purchase orders;
Developing systems and procedures, including management
information systems, for assuring compliance with the requirements
under the Act;
Preparing reports and other documents related to the Act;
and
Coordinating the resolution of audit findings.
B. Costs for goods and services reqiured for administration of the
system;
C. Costs of system-wide management functions; and
D. Travel costs incurred for official business in carrying out
grant management or administrative activities.
Selection Criteria
Under the School-to-Work Opportunities Implementation Grant
competition, the Departments will use the following selection criteria
in evaluating applications and will utilize a two-phase review process.
In the first phase, review teams, including peers, will evaluate
applications using the selection criteria and the associated point
values. In the second phase, review teams, including peers, will visit
high-ranking States to gain additional information and further assess
State plans. The following selection criteria will apply to both review
phases. The Departments will base final funding decisions on
information obtained during the site visits, the ranking of
applications as a result of the first-phase review, and such other
factors as replicability, sustainability, innovation, and geographic
balance and diversity of program approaches.
Selection Criterion 1: Comprehensive Statewide System
Points: 35.
Considerations: In applying this criterion, reviewers will
consider:
A. 20 points. The extent to which the State has designed a
comprehensive statewide School-to-Work Opportunities plan that--
Includes effective strategies for integrating school-based
and work-based learning, integrating academic and vocational education,
and establishing linkages between secondary and postsecondary
education;
Is likely to produce systemic change in the way youth are
educated and prepared for work and for further education, across all
geographic areas of the State, including urban and rural areas, within
a reasonable period of time.
Includes strategic plans for effectively aligning other
statewide priorities, such as education reform, economic development,
and workforce development into a comprehensive system that includes the
School-to-Work Opportunities system and support its implementation at
all levels--State, regional and local;
Ensures that all students will have a range of options,
including options for higher education, additional training and
employment in high-skill, high-wage jobs; and
Ensures coordination and integration with existing local
education and training programs and resources, including those School-
to-Work Opportunities systems established through local partnership
grants and Urban/Rural Opportunities grants funded under Title III of
the School-to-Work Opportunities Act, and related Federal, State, and
local programs.
B. 15 points. The extent to which the State plan demonstrates the
State's capability to achieve the statutory requirements and to
effectively put in place the system components in Title I of the
School-to-Work Opportunities Act, including--
The work-based learning component that includes the
statutory mandatory activities and that contributes to the
transformation of workplaces into active learning components of the
education system through an array of learning experiences, such as
mentoring, job-shadowing, unpaid work experiences, school-sponsored
enterprises, supported work experiences, and paid work experiences;
The school-based learning component that will provide
students with high level academic skills consistent with academic
standards that the State establishes for all students, including, where
applicable, standards established under the Goals 2000: Educate America
Act:
A connecting activities component to provide a functional
link between students' school and work activities and employers and
educators; and
A plan for an effective process for assessing students'
skills and knowledge required in career majors, and the process for
issuing portable skill certificates that are benchmarked to high
quality standards such as those the State establishes under the Goals
2000: Educate America Act, and for periodically assessing and
collecting information on student outcomes, as well as a realistic
strategy and timetable for implementing the process.
Selection Criterion 2: Commitment of Employers and Other Interested
Parties
Points: 15.
Considerations: In applying this criterion, reviewers will
consider:
The extent to which the State has obtained the active
involvement of employers and other interested parties listed in section
213(d)(5) of the Act, such as locally elected officials, secondary
schools and postsecondary educational institutions (or related
agencies), business associations, industrial extension centers,
employees, labor organizations or associations of such organizations,
teachers, related services personnel, students, parents, community-
based organizations, rehabilitation agencies and organizations,
registered apprenticeship agencies, local vocational educational
agencies, vocational student organizations, State or regional
cooperative education associations, and human service agencies, as well
as State legislators.
Whether the State plan demonstrates an effective and
convincing strategy for continuing the involvement of employers and
other interested parties in the statewide system, such as the parties
listed in section 213(d)(5) of the Act, as well as State legislators.
The extent to which the State plan proposes to include
private sector representatives as joint partners with educators in the
oversight and governance of the overall School-to-Work Opportunities
system. [[Page 26814]]
The extent to which the State has developed strategies to
provide a range of opportunities for employers to participate in the
design and implementation of the School-to-Work Opportunities system,
including membership on councils and partnerships; assistance in
setting standards, designing curricula and determining outcomes;
providing worksite experience for teachers; helping to recruit other
employers; and providing worksite learning activities for students,
such as mentoring, job-shadowing, unpaid work experiences, supported
work experiences, and paid work experiences.
Selection Criterion 3: Participation of All Students
Points: 15.
Considerations: In applying this criterion, reviewers will refer to
the definition of the term ``all students'' in section 4(2) of the Act
and consider:
The extent to which the State will implement effective
strategies and systems: to provide all students with equal access to
the full range of program components specified in sections 102 through
104 of the Act and related activities such as recruitment, enrollment
and placement activities; and to ensure that all students have
meaningful opportunities to participate in School-to-Work Opportunities
programs.
Whether the plan identifies potential barriers to the
participation of any students, and the degree to which the plan
proposes effective ways of overcoming these barriers.
The degree to which the State has developed realistic
goals and methods for assisting young women to participate in School-
to-Work Opportunities programs leading to employment in high-
performance, high-paying jobs, including nontraditional jobs and has
developed realistic goals to ensure an environment free from racial and
sexual harassment.
The feasibility and effectiveness of the State's strategy
for serving students from rural communities with low population
densities.
The State's methods for ensuring safe and healthy work
environments for students, including strategies for encouraging schools
to provide students with general awareness training in occupational
safety and health as part of the school-based learning component, and
for encouraging employers to provide risk-specific training as part of
the work-based learning component.
Note: Experience with the FY 1994 School-to-Work Opportunities
State Implementation Grant applications has shown that many
applicants do not give adequate attention to designing programs that
will serve school dropouts and programs that will serve students
with disabilities. Therefore, the Departments would like to remind
applicants that reviewers will consider whether an application
includes strategies to specifically identify the barriers to
participation of dropouts and students with disabilities and
proposes specific methods for effectively overcoming such barriers
and for integrating academic and vocational learning, integrating
work-based learning and school-based learning, and linking secondary
and postsecondary education for dropouts and students with
disabilities. Applicants are reminded that JTPA Title II funds may
be used to design and provide services to students who meet the
appropriate JTPA eligibility criteria.
Selection Criterion 4: Stimulating and Supporting Local School-to-Work
Opportunities Systems
Points: 15.
Considerations: In applying this criterion, reviewers will
consider:
The effectiveness of the State's plan for ensuring that
local partnerships include employers, representatives of local
educational agencies and local postsecondary educational institutions
(including representatives of area vocational education schools, where
applicable), local educators (such as teachers, counselors, or
administrators), representatives of labor organizations or
nonmanagerial employee representatives, and students, and others such
as those included in section 4(11)(B).
The extent to which the State assists local entities to
form and sustain effective local partnerships serving communities in
all parts of the State.
Whether the plan includes an effective strategy for
addressing the specific labor market needs of localities that will be
implementing School-to-Work Opportunities systems.
The effectiveness of the State's strategy for building the
capacity of local partnerships to design and implement local School-to-
Work Opportunities systems that meet the requirements of the Act.
The extent to which the State will provide a variety of
assistance to local partnerships, as well as the effectiveness of the
strategies proposed for providing this assistance, including such
services as: Developing model curricula and innovative instructional
methodologies, expanding and improving career and academic counseling
services, and assistance in the use of technology-based instructional
techniques.
The effectiveness of the State's strategy for providing
staff development to teachers, employers, mentors, counselors, related
services personnel, and others who are critical to successful
implementation of School-to-Work Opportunities systems for all youth.
The ability of the State to provide constructive
assistance to local partnerships in identifying critical and emerging
industries and occupational clusters.
Selection Criterion 5: Resources
Points: 10.
Considerations: In applying this criterion, reviewers will
consider:
The amount and variety of other Federal, State, and local
resources the State will commit to implementing its School-to-Work
Opportunities plan, as well as the specific use of these funds,
including funds for JTPA Summer and Year-Round Youth programs and
Perkins Act programs.
The feasibility and effectiveness of the State's long-term
strategy for using other resources, including private sector resources,
to maintain the statewide system when Federal resources under the
School-to-Work Opportunities Act are no longer available.
The extent to which the State is able to limit
administrative costs in order to maximize the funds spent on the
delivery of services to students, as required in section 214(b)(3)(B)
of the Act, while ensuring the efficient administration of the School-
to-Work Opportunities system.
Criterion 6: Management Plan
Points: 10.
Considerations: In applying this criterion, reviewers will
consider:
The adequacy of the management structure that the State
proposes for the School-to-Work Opportunities system.
The extent to which the State's management plan
anticipates barriers to implementation and proposes effective methods
for addressing barriers as they arise.
Whether the application includes an evaluation plan
containing feasible, measurable goals for the School-to-Work
Opportunities system, based on performance measures contained in
section 402(a) of the Act.
The extent to which the evaluation plan includes an
effective method for collecting information relevant to the State's
progress in meeting its goals, and is likely to assist the State to
meet its School-to-Work Opportunities system objectives, to gauge the
success of the system in achieving those objectives, to continuously
improve the system's effectiveness, and to contribute to the review of
results across all States.
Whether the plan includes a feasible workplan for the
School-to-Work Opportunities system that [[Page 26815]] includes major
planned objectives over a five-year period.
Additional Priority Points
As required by section 214(a)(1) and (a)(2) of the Act, the
Departments will give priority to applications that demonstrate the
highest level of concurrence among State partners with the State plan,
and to applications that require paid, high quality work-based learning
experiences as an integral part of the School-to-Work Opportunities
system by assigning additional points--above the 100 points described
in the criteria--as follows:
1. Highest Levels of Concurrence--5 Points
Up to 5 points will be awarded to applications that can--
Fully demonstrate that each of the State partners listed
in section 213(b)(4) concurs with the State School-to-Work
Opportunities plan, and that the State partners' concurrence is backed
by a commitment of time and resources to implement the plan.
2. Paid, High-Quality Work-Based Learning--10 Points
Up to 10 points will be awarded to applications that demonstrate
that the State--
Has developed effective plans for requiring, to the
maximum extent feasible, paid, high-quality work experience as an
integral part of the State's School-to-Work Opportunities system, and
for offering the paid, high-quality work experiences to the largest
number of participating students as is feasible; and
Has established methods for ensuring consistently high
quality work-based learning experiences across the State.
Program Authority: 20 U.S.C. 6101 et seq.
Dated: May 15, 1995.
Doug Ross,
Assistant Secretary for Employment and Training, Department of Labor.
Augusta Kappner,
Assistant Secretary for Vocational and Adult Education, Department of
Education.
Appendix--Analysis of Comments and Changes
Definition of Administrative Costs
Comment: Three commenters suggested that public relations and
evaluation were functions so central to the States' ability to
implement systemic change that they should be excluded from the
definition of administrative costs. One of the commenters also
recommended excluding monitoring and developing systems for assuring
compliance, for the same reason. One of these commenters suggested
that first-year costs to establish these activities might be
excluded, while maintaining the activities in future years could be
charged to administrative costs.
Discussion: The Departments agree that marketing (referred to as
``public relations'' in the notice of proposed selection criteria)
and evaluation are key State system-building functions. Developing
and maintaining a comprehensive statewide system will require change
on the part of a great many organizations and individuals and the
development of extensive partnerships at the State and local levels.
Communicating the need for such change and challenging different
groups to get involved--marketing--is an activity that is essential
to achieving a School-to-Work Opportunities system. In addition, the
evaluation function is especially critical because of the need for
an ongoing process of measuring system effectiveness. The
Departments believe, however, that monitoring and establishing
compliance systems are activities more appropriately charged to the
administrative cost category. The Departments expect that States
will be providing extensive assistance to local partnerships to
build their capacity to develop and implement local School-to-Work
systems that meet the requirements of Title I. This process of
forming and sustaining partnerships, which is addressed under
Criterion 4, should be designed to help prevent compliance problems.
Changes: The activities related to marketing and evaluation
against stated objectives have been deleted from the list of
activities that must be included in the administrative cost
category.
Restructuring Criteria
Comment: One commenter suggested restructuring the six criteria
around the two major responsibilities of a State under School-to-
Work Opportunities: (1) Developing and guiding a comprehensive
statewide system; and (2) supporting the local School-to-Work
Opportunities system. This commenter also recommended that the areas
for which additional points could be awarded (``Highest Levels of
Concurrence'' and ``Paid, High-Quality Work Experience'') should,
instead, be incorporated into one of the other criteria.
Discussion: The Departments agree that distributing the criteria
around the two major responsibilities identified might be a useful
alternative way to structure the criteria. However, other than
repositioning the bullets, the recommendation did not include
changing or deleting any of the bullets. In addition, the
Departments do not agree that the areas for which additional points
may be awarded could be incorporated into one of the selection
criteria. Section 214 of the School-to-Work Opportunities Act of
1994 (the Act) requires that priority be given to applications that
demonstrate the highest levels of concurrence among State partners
and to applications that require paid, high-quality work experience.
Subsuming these areas within other selection criteria is not
consistent with the priority required by the Act. On balance, the
Departments are confident that the current structure of the
selection criteria adequately reflects the elements of a
comprehensive State School-to-Work Opportunities system.
Changes: None.
Selection Criterion 1: Comprehensive Statewide System (A)
Postsecondary Involvement
Comment: One commenter stated that the criteria did not address
possible duplication of effort between School-to-Work Opportunities
systems and programs established in public educational institutions,
such as local community colleges. This commenter was concerned that
localities might limit community college involvement, while favoring
programs funded under the Department of Labor's Job Training
Partnership Act. The commenter stated that the notice should include
points for applications that promote the participation of local
postsecondary institutions and community colleges, and also ``should
address local secondary school participation.''
Discussion: The School-to-Work initiative is designed to unify
categorical programs into coherent and comprehensive systems, and
the Departments believe that the law and the notice adequately
address duplication of effort. Coordination with, and integration of
existing programs, including those in place in community colleges,
is a key feature of School-to-Work Opportunities systems. An
approved State plan must include strategies for effectively linking
secondary and postsecondary education and the plan must describe
coordination with programs funded under a range of authorities,
including the Adult Education Act, the Perkins Act, the Elementary
and Secondary Education Act (ESEA), and the Higher Education Act
(see section 213(d)(6) of the Act). State partnerships must include
State agency officials responsible for postsecondary education, and
the notice awards priority points to applications that demonstrate
partners' full concurrence with the School-to-Work Opportunities
plan. Under Criterion 2: ``Commitment of Employers and Other
Interested Parties,'' applicants must describe the State's efforts
to obtain and maintain the substantive participation of a range of
stakeholders. In response to several comments, Criterion 2 has been
changed to explicitly list the examples of interested parties as
given in section 213(d)(5) of the Act, including secondary schools
and postsecondary educational institutions, so that applicants are
reminded of the range of organizations that might contribute to the
effectiveness of the School-to-Work Opportunities system. Also in
response to comments, Selection Criterion 4: ``Stimulating and
Supporting Local School-to-Work Opportunities Systems'' now lists
the required members of local partnerships as given in the Act,
including local educational agencies and local postsecondary
institutions, and applications must show how the State will assist
communities in developing effective local partnerships. Given these
specifications, the final notice makes it more explicit that only
applications that demonstrate the genuine involvement of local
secondary schools, community colleges, and other postsecondary
institutions in their School-to-Work systems, will be competitive.
While the Departments support State and [[Page 26816]] local
flexibility in deciding which networks form the most appropriate
base from which to expand School-to-Work Opportunities systems, the
Departments also believe it is highly unlikely that an effective
system can be built with only limited, selective participation of
the stakeholders mentioned in the Act. In response to the comment
about the need to address local secondary school participation, the
Departments wish to stress that any application that under Criterion
1 B fails to present a convincing plan for institutional change in
secondary schools statewide, will not be competitive.
Changes: None.
Preparation for Entry Into Four-Year Colleges
Comment: One commenter was concerned that comprehensive School-
to-Work Opportunities systems would be associated with vocational
education; the commenter believed vocational education is negatively
viewed as yielding few academic skills, limiting postsecondary
options, and limiting access to careers that require postsecondary
education. The commenter believed that Criterion 1 should require
reviewers to consider the extent to which plans ensure that all
students graduating from secondary school will be ``eligible'' to
enter four-year colleges.
Discussion: School-to-Work Opportunities systems must prepare
learners for a range of education, employment and training options,
as discussed throughout the Act and highlighted in the notice of
proposed selection criteria in the first, second and fourth bullets
of Criterion 1. School-to-Work aims at developing a lifelong
continuum of learning and work experience, rather than targeting a
specific type of institution or course of study. The Departments
agree with the commenter on the need to emphasize to parents,
students, and other stakeholders that School-to-Work Opportunities
systems will not limit, but rather enhance, all students' capacity
to master concepts and successfully enter and complete four-year
degree programs. Since they utilize new methods of teaching,
learning, assessing and demonstrating student achievement, School-
to-Work Opportunities systems will also require flexibility and
support from employers and four-year institutions for new methods of
measuring student performance, such as skill certificates and
portfolios. Although the Departments do not believe that a specific
reference to ``eligibility'' for four-year colleges is necessary,
they wish to stress that the success of student transitions will
depend in part on the commitment of employers and postsecondary
institutions to develop and accept new measures of student
performance resulting from educational reform.
Changes: None.
K-Adult Continuum
Comment: One commenter suggested that language be added to
support a State School-to-Work Opportunities plan that addresses all
students, from K-Adult.
Discussion: The Departments believe that the criteria, as
written, address life-long learning in many respects. Reviewers will
evaluate the extent to which a State's implementation plan
integrates education and training programs and resources, including
those which serve adults, such as postsecondary, continuing
education, existing worker training and registered apprenticeship
programs. Also, the Departments expect that a State's partnership
will include a range of entities (see sections 213(b)(4) and
213(d)(5) of the Act), many of which relate directly to adult
learners and workers. Finally, the most comprehensive plans for
education reform will be strongly tied to related statewide
initiatives such as economic development and workforce development,
with School-to-Work as the framework for a K-Life continuum.
Therefore, the Departments anticipate that the most competitive
applications will address life-long learning implicitly in the
implementation plan, or will achieve this integration in the long
term.
Changes None.
Focus on Communities With High Concentrations of Poor and
Disadvantaged Youth
Comment: One commenter suggested that the second bullet of
Criterion 1 A, which refers to the State's plan for systemic change,
include specific mention of communities with high concentrations of
poor and disadvantaged youth.
Discussion: The Departments believe that Criterion 1 A, by
considering the extent to which the School-to-Work Opportunities
system is likely to encompass and produce change in all areas
statewide, addresses the inclusion of communities with high
concentrations of poor and disadvantaged youth. Applications that do
not outline convincing strategies and timelines for achieving
comprehensive statewide coverage will be less competitive than those
that do. In addition, the second bullet in the now-revised Criterion
4 places further weight on the State's plan to actively assist local
partnerships in expanding the system to reach communities in all
parts of the State. Reviewers will evaluate whether there are gaps
in the strategy for implementing the School-to-Work Opportunities
system throughout the State and score the application accordingly.
Changes: None.
Apprenticeship Training
Comment: One commenter expressed the view that apprenticeship
training be included in Criterion 1 A with education reform,
economic development, and workforce development, as statewide
priorities in the establishment of a comprehensive system. The
commenter also believed that the work-based learning component in
Criterion 1 B should include, as a potential learning experience,
early entry into apprenticeship training.
Discussion: In Criterion 1, ``education reform,'' ``economic
development,'' and ``workforce development'' are broad terms that
are intended to include a variety of programs and activities that
may be part of a State's strategic priorities. The Departments
believe that apprenticeship training is likely to be a key component
in many comprehensive workforce development strategies; however,
they do not want to suggest that any specific program must be part
of a State's workforce development initiative. In regard to the
suggestion that early entry into apprenticeship training be included
in the bullet on work-based learning on Criterion 1 B, the
Departments agree that early entry into an apprenticeship program
can be an appropriate objective for a School-to-Work Opportunities
program. Section 215(b) (4) (K) of the Act includes, as an allowable
activity for local partnerships receiving subgrants from States, the
creation or expansion of school-to-apprenticeship programs in
cooperation with registered apprenticeship agencies and
apprenticeship sponsors. However, the extent to which apprenticeship
training is utilized as a work-based learning experience in a
statewide system is most suitably determined by the State.
Changes: None.
System Change for Youth With Disabilities
Comment: Several commenters recommended requiring special plans
to demonstrate how School-to-Work Opportunities programs will be
coordinated with ``systems change grants'' and other related
activities under the Individuals with Disabilities Education Act
(IDEA). In order to ensure participation by youth with disabilities,
these commenters suggested that Criterion 1 A be revised to
specifically reference IDEA transition projects or Systems Change
for Youth with Disabilities.
Discussion: Achieving comprehensive reform will require States
to coordinate and integrate a great number and variety of State
initiatives having related goals. The Departments agree that the
lessons learned from initiatives and programs that are related to
School-to-Work should be incorporated into the State's comprehensive
plan. The fifth bullet under Criterion 1 A is intended to encourage
States to review the many related Federal, State and local programs
and initiatives and develop strategies for creating mutually
supportive strategies.
Changes: None.
Selection Criterion 1: Comprehensive Statewide System (B)
Emphasis on Coordination With Goals 2000
Comment: Several commenters expressed concern about the
relationship between School-to-Work and the Goals 2000: Educate
America Act. The commenters emphasized the voluntary nature of
States' participation in Goals 2000 activities, and believed that
the notice linked academic and skills standards too closely to these
activities rather than focusing more broadly on statewide education
reform initiatives. Conversely, one commenter stated that the
criteria did not highlight strongly enough the importance of the
State's role in developing curricula and instructional methodologies
consistent with academic and skill standards such as those
established under Goals 2000, nor in ensuring that students achieve
these standards. One commenter noted that the use of the past tense
in referring to standards ``established'' under Goals 2000 implies
that States have submitted standards for certification by The
National Education [[Page 26817]] Standards and Improvement Council.
(The Council is provided for under Goals 2000, but has not been
formed.) One commenter believed that the Goals 2000 standards apply
only to traditional academic subject areas, disregarding core
standards and performance measures for vocational and technical
education already being developed by States under the Perkins Act,
and separating academic performance from performance related to
workforce-development. This commenter stated that a reference in
Criterion 2 to employer involvement in the development of standards
was the only linkage to the performance-based system being built
under the Perkins Act.
Discussion: The Departments wish to clarify that participation
in activities under both Goals 2000 and School-to-Work is strictly
voluntary, and that participation in Goals 2000 is in no way a
condition for receiving a School-to-Work Opportunities
Implementation Grant. However, in the case of States that have
chosen to participate in Goals 2000, the Departments will consider
whether plans developed under School-to-Work and Goals 2000 are
coordinated and mutually reinforcing. A major focus of Criterion 1
is the need to integrate School-to-Work into the State's overall
agenda for education reform or restructuring. The Departments intend
to emphasize the need for high, statewide standards against which to
develop curriculum, measure the quality of integrated school-based
and work-based learning and instruction, assess learner performance,
and certify proficiency. The notice refers to standards developed
under Goals 2000 as an example of such State-developed and validated
measures. In response to the comment that Goals 2000, and, by
association, this notice, disregards significant work already
undertaken through the Perkins Act, the Departments would point out
that under Goals 2000, participating States must coordinate their
improvement plans both with any School-to-Work efforts and with
strategies to integrate academic and vocational instruction as
outlined in the Perkins Act. (See Goals 2000, section 306(j) and
(1).) The School-to-Work Opportunities Act defines the integrated
work-based and school-based components as incorporating, to the
extent possible, all aspects of the industry, and providing
academic, vocational, technical and production skills as well as
general workplace competencies (see sections 4(1), 101 and 102 of
the Act). Whether education reform and standards development occur
independent from, or in relation to, the Goals 2000 initiative, it
is important that the School-to-Work Opportunities plan unfold in
the context of a systematic vision for improving education in the
State.
Changes: None.
Need To Include Sections of the Act in the Notice
Comment: One commenter believed that the criteria should more
exactly reiterate definitions and key components contained in the
Act in section 4 (``Definitions'') and Title I, sections 101-104
(``General Program Requirements'' and basic program components),
with specific points assigned for elements such a those described in
section 213 (d) (``State Plan'') of the Act. The commenter also
suggested that the Departments restore language, included in the Act
but omitted from the final bullet of Criterion 1 B, linking career
majors to the assessment and certification of skills. In the opinion
of the commenter, the exclusion of this reference from the criterion
altered the meaning of this section.
Discussion: While the Departments concur with the commenter on
the importance of these provisions, they do not believe it is
necessary to restate in the notice most of the legislative language
emphasized by the commenter, or that it is necessary to assign
points for every statutory requirement. The notice advises States
that applications must meet all the requirements of the Act,
reiterates that all definitions in the Act apply to systems funded
under the State Implementation Grant competitions, and emphasizes,
under Criterion 1, the need for State plans to demonstrate
consistency with all statutory requirements and with all system
components in Title I of the Act. Therefore, the Departments
strongly encourage applicants to refer to the Act as well as the
criteria in developing School-to-Work Opportunities plans which
reflect the full intent of the law. The Departments wish to assure
the commenter that panelists reviewing the applications are selected
for their understanding of the School-to-Work Opportunities Act, are
required to participate in a carefully designed orientation, and
must score applications based on the criteria, in conjunction with
the requirements of the Act. The Departments agree with the
commenter that the bullet relating to assessment and certification
of skills would be strengthened and clarified by including a
reference to career majors, as given in section 213(d)(16) of the
Act.
Changes: The final bullet in Criterion 1 B now includes the
language of section 213(d)(16) of the Act regarding the State's
process for assessing skills and knowledge required in career
majors.
Distribution of Points
Comment: One commenter questioned the distribution of points in
this section, and believed that Criterion 1 B, under Comprehensive
Statewide System, should receive more weight than 15 out of 100
points. Another commenter recommended that the points assigned to
Criterion 3, ``Participation of All Students,'' be increased from 15
to 20.
Discussion: In response to this comment, the Departments gave
careful consideration to the distribution of points among the
selection criteria, and have concluded that the distribution
provided for in the notice results in the most appropriate balance
among the criteria.
Changes: None.
Supported Work
Comment: One commenter recommended adding supported work
activities or experiences to several criteria to highlight what can
be done at the work site to assist students with disabilities.
Discussion: The Departments agree that supported work
activities, that provide individualized support to assist persons
with severe disabilities in becoming equal participants in the
competitive labor force, can be appropriate elements of the work-
based learning component.
Changes: in Criterion 1 B, the phrase ``supported work
activities'' has been added to the list of learning experiences that
may be included in work-based learning. In addition, in Criterion 2,
the term ``supported work experiences'' has been added to the list
of opportunities for employers' participation.
Selection Criterion 2: Commitment of Employers and Other Interested
Parties
Key Stakeholders
Comment: Many commenters were concerned that by not specifically
referencing organized labor as a party that should be actively
involved in the development of the State system, as employers and
State legislators are referenced, labor's contribution to the
School-to-Work Opportunities initiative would be diminished. Various
commenters also indicated that teachers, vocational rehabilitation
agencies, JTPA service providers, community-based organizations,
private non-profits, parents, and/or consumers should be explicitly
identified as key stakeholders in the State system since the
inclusion of these entities is as vital to the development of the
system as that of employers.
Discussion: While the proposed criterion referenced section
213(d)(5) of the Act, which, in turn, explicitly lists the parties
the State may involve in the creation of a statewide School-to-Work
Opportunities system, the Departments agree that it would be helpful
to identify expressly in the first bullet of Criterion 2 all of the
parties referred to in section 213(d)(5). In this way, the criterion
does not appear to exclude any of the entities that have significant
contributions to make to the establishment of a comprehensive
School-to-Work Opportunities system. Although the Departments
believe that labor organizations have unique contributions to make
to the design and implementation of School-to-Work Opportunities
systems, Criterion 2 retains State flexibility to determine the
involvement of specific interested parties listed in section
213(d)(5) of the Act. The Departments concur with the rationale
expressed by several commenters that developing high-quality work-
based learning experience requires the commitment of front-line
workers as well as top-level managers and CEOs. Applicants are
encouraged to utilize labor organizations and other key parties
toward this aim.
Changes: Selection Criterion 2 has been changed to recognize all
the entities listed in section 213(d)(5) of the Act.
Involvement of Teachers
Comment: One commenter believed that the involvement of teachers
should be augmented beyond being listed among ``other interested
parties.'' This commenter recommended that teachers be designated as
required sponsors of any grant application. This commenter, as well
as one other, believed that applicants that articulate
[[Page 26818]] convincing strategies to ensure effective and
sustained teacher involvement at both the State and local levels
should receive additional points.
Discussion: The Departments strongly encourage State teams to
involve teachers at every stage of system development and
implementation. A School-to-Work Opportunities system that does not
effectively incorporate the needs, beliefs, and capabilities of
classroom educators will not be able to reach the comprehensiveness
required of system implementation. Additionally, strategies for
building upon the current practices within a State will not be
realistic or complete without the input of teachers. Although the
Departments believe that teachers have unique contributions to make
to the design and implementation of School-to-Work Opportunities
systems, Criterion 2 retains State flexibility to determine the
involvement of specific interested parties listed in section
213(d)(5) of the Act. Also, consistent with section 213(b)(4) of the
Act, the Departments do not believe it is appropriate to mandate
teacher sponsorship of the grant application. Finally, it is
noteworthy that the importance of teachers' participation in School-
to-Work Opportunities systems is further conveyed by the specific
reference to teachers within the definition of ``local
partnership,'' in section 4(11)(A) of the Act. That section provides
that local partnerships must include, among others, ``local
educators (such as teachers, counselors, or administrators) * * *''
Changes: As stated above, Criterion 2 now includes reference to
each entity listed in section 213(d)(5) of the Act. Selection
Criterion 4 has been changed to add, as its first bullet, the
ability of the State to ensure that local partnerships include all
of the entities listed in section 4(11)(A) of the Act.
Consultation With Organized Labor
Comment: Several commenters supported the addition of a
requirement that the State directly consult with the State AFL-CIO
in order to coordinate organized labor involvement at both the State
and local levels. Many commenters supported this concept by
requesting that the Departments require States to define a
particular role for organized labor, tie this requirement to
Criterion 2, and assign points to the requirement. Lastly, one
commenter believed that it would be appropriate to include a special
note requesting that States develop distinctive strategies to
utilize organized labor.
Discussion: The Departments agree that organized labor is a key
contributor to the development and implementation of comprehensive
School-to-Work Opportunities systems. As many commenters suggested,
labor organizations have significant contributions to make in a
variety of aspects of such systems--from designating workplace
mentors and helping to ensure safe work environments to the
establishment of realistic skill standards. The Act thoroughly
delineates who must collaborate in the development of a statewide
system, as stated in section 213(b)(4) of the Act, which includes
representatives of the private sector, as well as the other
interested parties who are encouraged to be involved, as stated in
section 213(d)(5) of the Act which includes ``labor organizations or
associations of such organizations.'' The Departments do not believe
that it is appropriate to mandate additional requirements beyond
those contained in the Act or to define a role for any stakeholder
group; however, strong applications will be those that represent the
greatest amount of collaboration among stakeholders. Applicants are
reminded that labor organizations or nonmanagerial employee
representatives are required members of local partnerships in the
School-to-Work Opportunities system, and, in response to another
comment, Criterion 4 now identifies all required members of local
partnerships.
Changes: None.
Bureau of Apprenticeship and Training Involvement
Comment: One commenter suggested that States designate a Federal
Bureau of Apprenticeship and Training (BAT) representative as a
State partner in order to avoid any duplication of effort between
established apprenticeship programs and School-to-Work activities
being developed as a result of the Act. The commenter referenced the
Act's specificity with regard to non-duplication of effort.
Discussion: Section 213(d)(5) of the Act, referenced in
Criterion 2, includes registered apprenticeship agencies as entities
that States may actively and continually involve in the development
and implementation of statewide systems. The term ``registered
apprenticeship agency'' is defined under section 4(13) of the Act to
mean ``the Bureau of Apprenticeship and Training in the Department
of Labor or a State apprenticeship agency recognized and approved by
the Bureau of Apprenticeship and Training as the appropriate body
for State registration or approval of local apprenticeship programs
and agreements for Federal purposes.'' Since Criterion 2 has been
changed to identify all entities listed in section 213(d)(5) of the
Act, and since the Act includes the Bureau of Apprenticeship and
Training in its definition of ``registered apprenticeship agency,''
the Departments believe that the criteria adequately allow for the
inclusion of the Bureau of Apprenticeship and Training in State
system-building activities.
Changes: None.
Selection Criterion 3: Participation of All Students
Participation of Target Groups
Comment: Many commenters suggested ways to emphasize the
participation of a particular target group or groups included in the
definition of ``all students.'' Some commenters recommended
requiring specific strategies or plans for one or more of the target
groups. Some believed that the ``Note'' on students with
disabilities and dropouts was helpful, but that the concept of
developing strategies for students with disabilities and school
dropouts would be strengthened if it were added as a separate
consideration in Criterion 3. One commenter wanted to add a ``Note''
reminding applicants of the importance of nontraditional employment
for women in School-to-Work and asking for identification of
barriers and methods for overcoming them. One commenter suggested an
alternative method for addressing the participation of all students.
The commenter was concerned that assigning 15 points to a criterion
that included all types of students might permit continuation of
historical exclusionary practices because applicants could provide
strong strategies for some students, but not include others and
still be awarded high marks on this criterion.
While most of the comments relating to participation of target
groups recommended requiring specific strategies for a particular
target group, one commenter did not want to focus on any special
group. This commenter believed that the strength of the School-to-
Work Opportunities Act is that it is designed for all students, and
that the system itself is the solution for different groups.
Recommendations for where in the notice changes should be made
included Criteria 1, 3 and 4. Although most commenters wanted States
to be required to provide more specific attention to a particular
group in Criterion 3, several suggested adding language to the
fourth bullet in Criterion 1A in order to correct past histories of
exclusion or to help raise State awareness that the range of options
should be available to a specific target group or groups. One
commenter recommended adding language to Criterion 4 that would
encourage States to help local systems use technology-based
instructional techniques for students with disabilities. Another
commenter recommended replacing Criterion 3 with what was referred
to as a ``threshold criterion.''
Discussion: Criterion 3 requires a State to describe its
strategies for effectively ensuring opportunities for all students
to participate, and to identify ways of overcoming barriers to the
participation of any students. The additional considerations in this
criterion for young women and for students from rural communities
with low population densities reflect the required content of the
State plan, as described in section 213(d) of the Act. Balancing the
design of a system that serves all students with the need for
targeted strategies for some students is one of the most difficult
aspects of implementing the School-to-Work Opportunities initiative.
Like the Act, Criterion 3 refrains from requiring applicants to
design specific programs for each specific group of students.
Rather, the focus is on building a system for all students. The
Departments agree that to receive the maximum points on Criterion 3
applicants must not neglect the needs of any students, and must
convincingly describe how the State's School-to-Work Opportunities
system will provide the same options and produce the same results
for all participating students, while recognizing that groups of
students have different needs and, therefore, that specific
strategies may be required for the target groups listed in the
definition of ``all students.'' Applications that fail to address
the critical needs of each category of student and fail to develop
effective strategies based on identified student needs will not be
as competitive as applications that have
[[Page 26819]] comprehensive and effective strategies for all
students. To be competitive, States that have not fully established
all components of the strategies devised for all students, should
have at least a timetable for putting all aspects of their
strategies in place within a reasonable period of time. Finally, the
Departments do not agree that Criterion 3 should be replaced with a
threshold criterion or an eligibility requirement or that either of
these would be consistent with the Act.
Changes: A reference to the definition of ``all students'' in
section 4 of the Act has been added to Criterion 3 in order to
remind applicants of the scope of the term.
Define ``All Students''
Comments: Several commenters suggested that a definition of the
term ``all students'' be added in the Definitions section of the
Notice or that the specific student categories be defined. The
commenters believed that the notice of final priority and selection
criteria for the FY 1994 competition was clearer about the
definition and that the significance of the requirement for ``all
students'' needed to be emphasized.
Discussion: The final competition for State Implementation
Grants in 1994 was announced prior to passage of the School-to-Work
Opportunities Act. Consequently, it was necessary last year to
provide more detailed information and definitions in the Notice--
anticipating the School-to-Work Opportunities legislation--while
ensuring consistency with Cooperative Demonstration authority of the
Carl D. Perkins Vocational and Applied Technology Education Act,
under which the FY 1994 State Implementation Grant awards were
funded. For this second round of competitions, all definitions and
requirements of the Act apply. However, the Departments agree that
it would be helpful to remind applicants that the definition of the
term ``all students'' applies to this competition.
Changes: A reference to the definition of ``all students'' in
section 4(2) of the Act has been included in Criterion 3.
Equal Access
Comment: Two commenters recommended that Criterion 3 be expanded
to include language requiring equal access to program components for
all students. One of these commenters also recommended that
Criterion 3 should require equitable representation of all students
and equal access at the inception of the grant. The equal access
language in Title I of the Act was considered by the commenter to be
the cornerstone to ensuring participation of all students.
Discussion: Section 101 of the Act defines the general program
requirements for all School-to-Work Opportunities systems and
requires that they ``provide students with equal access to the full
range of such program components (including both school-based and
work-based learning components) and related activities, such as
recruitment, enrollment, and placement activities, except that
nothing in the Act shall be construed to provide any individual with
an entitlement to services under this Act.'' As noted elsewhere in
this Appendix, applicants were reminded in the notice of proposed
selection criteria, and will be reminded in the final application
package, that applications must meet all requirements of the Act.
However, the Departments agree that the requirement for equal access
is so central to the purpose of School-to-Work Opportunities, that
applicants should be reminded that programs must provide equal
access to the full range of program components to all students.
In regard to the comment suggesting that equal access be
required from the inception of the grant, the Departments believe
that some States may have an effective plan for a comprehensive
School-to-Work Opportunities system even if all components of their
plans, including their strategy for ensuring equal access to the
full range of School-to-Work Opportunities program components, would
not be fully operational at the beginning of the Implementation
Grant period. However, in order to be competitive, a State should be
able to: (1) Demonstrate an effective strategy for assisting all
students to take advantage of the opportunities to fully participate
in a School-to-Work Opportunities program that meets the
requirements of Title I, and (2) describe the timetable for fully
implementing the strategy.
Changes: Language from section 101(5) of the Act relating to
equal access has been added to Criterion 3.
Monitoring
Comment: Several commenters recommended that State be asked to
provide specific detail on how they plan to monitor the safe and
healthy work environments that are required under section 601 of the
Act. Some of these same commenters believed that joint labor-
management safety committees and the State AFL-CIO should be
consulted in designing the monitoring mechanisms.
Discussion: Under Criterion 3, reviewers will consider the
State's methods for ensuring safe and healthy work environments for
students. Many activities may be a part of a State's strategy for
ensuring that students are provided safe and healthy work
environments, including risk assessment, assignment of
responsibility for safety, and monitoring. However, although the
Departments do not believe it is appropriate for them to define the
components of the strategy that all States must use to ensure safe
and healthy work environments, the bullet has been modified to
clarify that State strategies should include both school-based and
work-based components.
Furthermore, while the Departments agree that labor-management
safety committees would be in an excellent position to provide
assistance in designing monitoring mechanisms, the School-to-Work
Opportunities Act provides States with flexibility to develop and
implement School-to-Work Opportunities systems that best fit the
needs of the State, while meeting the requirements of the Act. Who
is involved in designing pieces of the State's system will be
determined by the State and local partners.
Changes: The final bullet of Criterion 3 has been modified to
encourage safety training to be included in both the school-based
and work-based components.
Work Environment Free From Harassment
Comment: One commenter recommended that States be required to
explain how they will ensure that student work environments are free
from racial and sexual harassment.
Discussion: The Departments agree that providing environments
for students that are free from racial and sexual harassment is an
important aspect of School-to-Work. Section 213(d)(14) of the Act
directs States to describe the State's goals and methods for
addressing the issues of participation in School-to-Work programs by
young women. That section also requires States to describe their
``goals to ensure an environment free from racial and sexual
harassment.'' The purpose of publishing the ``Notice of proposed
selection criteria'' was to provide an opportunity for comment on
the criteria that reviewers would use in evaluating applications; it
was not to repeat the entire contents of the State plans, as defined
in section 213(d). However, the Departments agree with the commenter
on the importance of the efforts of States and local partnerships to
ensure that students are provided with work environments, free from
racial and sexual harassment.
Changes: The phrase from section 213(d)(14) of the Act, ``and
has developed realistic goals to ensure an environment free from
racial and sexual harassment,'' has been added to the third bullet
under Criterion 3.
Focus on Communities With High Concentrations of Poor and
Disadvantaged Youth
Comment: One commenter suggested that the section that deals
with the State's strategy for serving students from rural
communities with low population densities include a specific
reference to communities with high concentrations of poor and
disadvantaged youth.
Discussion: Since Criterion 3 considers the extent to which the
School-to-Work Opportunities system is designed to reach all
students, the Departments believe the notice adequately addresses
the inclusion of such communities in the State's plan for
implementing systemic change across all geographic areas of the
State. Disadvantaged students are specifically noted in the Act's
definition of ``all students.'' (See section 4(2).) Applications
that do not outline convincing strategies for including all students
in the School-to-Work Opportunities system will be less competitive
than those that do.
Changes: None.
Alternative Assessments
Comment: Several commenters noted the importance of providing
flexibility in assessment processes. Some of these commenters
suggested adding considerations to Criterion 3 that encourage the
development of alternative assessment techniques and alternative
methods of meeting skill benchmarks that do not penalize students
for a deficit related to the assessment technique being utilized.
Discussion: The Act provides flexibility for States to design
School-to-Work Opportunities systems that respond to the unique
needs and opportunities of each [[Page 26820]] State. The State plan
that is part of the application for a State Implementation grant
must include a description of the State's processes for assessing
skills and knowledge required in career majors and for awarding
skill certificates. In addition, under Criterion 3, reviewers will
assess the extent to which the applicant has identified barriers to
the participation of any students.
Changes: None.
Selection Criterion 4: Stimulating and Supporting Local School-to-Work
Opportunities Systems
Stakeholder Involvement at the Local Level
Comment: Two commenters suggested that States be asked to
describe their efforts to involve organized labor at the local
level, including recommended strategies for local areas to address
labor market needs and build the capacity of their local
partnerships by involving labor organizations during the early
stages of initiative development. An additional commenter asked that
States be required to ensure that local partnerships include
students and community-based organizations in the development of
local School-to-Work Opportunities systems.
Discussion: Section 4(11)(A) of the Act states that local
partnerships must include: employers, representatives of local
educational agencies and local postsecondary educational agencies
(including representatives of area vocational education schools,
where applicable), local educators (such as teachers, counselors, or
administrators), representatives of labor organizations or
nonmanagerial employee representatives, and students. In addition,
section 215(c)(2) of the Act lists conducting ``outreach activities
to promote and support collaboration, in School-to-Work
Opportunities programs, by businesses, labor organizations, and
other organizations'' as an activity in which the State may become
involved in carrying out the statewide School-to-Work Opportunities
system. Bearing these points in mind, the Departments believe that
the most competitive State applications will contain strategies for
local areas that promote high levels of local partnership
collaboration and that can effectively demonstrate an awareness of a
local partnership's capability for inclusion of all parties
necessary for local initiative implementation and correlation to the
statewide system.
Changes: Selection Criterion 4 now includes, as its first
bullet, the ability of the State to ensure that local partnerships
include all of the entities listed in section 4(11)(A) of the Act.
Staff Development
Comment: Two commenters requested that staff development be
included in Criterion 4. One commenter focused on requiring States
to set aside resources and develop a long-term plan for providing
staff development activities to all staff members within secondary
schools. The other commenter indicated that State applications
should be assessed based upon their efforts to provide training for
teachers, employers, mentors, counselors, and other staff that
includes specialized training directed toward preparing women,
minorities, and individuals with disabilities for jobs in high-
skill, high-wage industries.
Discussion: The Departments agree with both commenters and
believe that the most competitive State applications will include
strategies for providing staff development for all who are involved
in the provision of School-to-Work activities for youth. Section
213(d)(7) of the Act expressly requires that States articulate
strategies for training teachers, employers, mentors, counselors,
related services personnel, and others, including specialized
training to prepare staff to effectively support special student
populations such as women, minorities, and individuals with
disabilities. Two other sections in the Act, section 104 (with
regard to the connecting activities component) and section 215(b)(4)
(with regard to allowable activities under State subgrants),
underscore the training of teachers, mentors, and others as vital
components of any School-to-Work Opportunities initiative. Since the
Act so strongly emphasizes the critical importance of staff
development in the implementation of statewide systems, and further
emphasizes the need for staff development at the local level, the
Departments are adding explicit language that compels reviewers to
consider the extent to which states have provided for staff
development for all staff involved in the provision of School-to-
Work activities for youth.
Changes: Selection Criterion 4 now includes an additional bullet
that considers the effectiveness of the State's strategy for
providing staff development to those who are critical to successful
implementation of School-to-Work Opportunities systems for all
youth.
Criterion 6: Management Plan
Evaluation
Comment: Several commenters were concerned that an evaluation
plan was not specifically required in State applications. The
commenters indicated that the presence of a concrete plan for
research and evaluation would help gauge a State's ability to
measure the success of, and to continuously improve, its School-to-
Work Opportunities system. Several commenters pointed out that the
resulting information could be used to systematically assess the
impact of School-to-Work systems, avoid duplication, identify
issues, challenges and best practices, and provide models for
replication. One commenter recommended that grantees collect data on
the number of exiting participants who are gaining employment and/or
entering and completing post-secondary education or training. One
commenter stated that performance measures are more than a
management issue, and should be considered under Criteria 1 and 4.
Discussion: The Departments believe that States should have the
flexibility to design evaluations appropriate to State needs and
goals, but they agree on the importance of a plan that presents how
a State will collect and analyze information related to the
performance measures in section 402 of the Act, as well as any other
factors the State deems necessary. Since the Departments are
required to conduct an evaluation of all systems funded under the
Act, information on the impact of School-to-Work will be gathered.
(See sections 401-404.) The Departments believe that the notice
sufficiently emphasizes the significance of performance measures.
However, the Departments agree with the commenters that Criterion 6
should relate performance measures and data collection methods to a
systematic evaluation plan. Reviewers will consider first, whether
such a plan is in place, second, the extent to which it is likely to
meet State objectives, third, the extent to which it will be used to
gauge the success of, and continuously improve, the State's School-
to-Work system, and fourth, the extent to which the State's
evaluation plan is likely to contribute to the review of results
across all States.
Changes: Criterion 6 has been changed to add the words
``evaluation plan'' as the vehicle for including measurable goals,
and to include in the bullet the ability of the evaluation plan to
meet State objectives, continuously improve the State system, and
contribute to the review of results across all States.
Addressing Potential Barriers
Comment: One commenter proposed involving organized labor to
address the potential barrier of providing all students with work-
based learning experiences. The commenter believed that the early
inclusion of ``member employers of organized labor'' would ensure
full participation of students in the School-to-Work Opportunities
initiative.
Discussion: The Departments encourage States to involve
representatives of organized labor and others in addressing such
potential barriers as providing all students with work-based
learning experiences. As stated in reference to Criterion 2, the
Departments have agreed to identify each of the entities listed in
section 213(d)(5) of the Act as stakeholders important to the
implementation of the statewide School-to-Work Opportunities system.
The Departments encourage the utilization of each of these entities,
including organized labor, in identifying and addressing potential
barriers to student participation and view the change to Criterion 2
as addressing this commenter's concerns as well.
Changes: None.
Additional Priority Points [1]--Highest Levels of Concurrence
Highest Levels of Concurrence
Comment: Three commenters made recommendations for change to the
section of the Notice on additional priority points for Highest
Levels of Concurrence. One commenter requested that, in addition to
awarding priority points for concurrence of the State partners, a
penalty for nonconcurrence should be applied. Another commenter
believed that five additional priority points for this criterion was
not appropriate because the basis for assigning the additional
points was not clear, and it would be difficult for reviewers to
differentiate between perceived and actual collaboration. Another
commenter believed that this section should be revised to encourage
States to utilize staff who are [[Page 26821]] qualified to deliver
services to special population groups.
Discussion: In response to the first comment, the Departments
note that reviewers may add a maximum of 5 points for applications
that demonstrate that all State partners listed in section 213(b)(4)
concur with the plan and have committed time and resources to
implementing it. Applications that do not fully demonstrate such
concurrence will receive less than 5 points, which is, in effect, a
penalty for nonconcurrence, as the commenter suggested. Regarding
the second suggestion, the Departments note that the basis for
awarding 5 additional points for ``Highest Levels of Concurrence''
is adequately described. To assist reviewers in differentiating
between perceived collaboration and actual collaboration, applicants
must show how the concurrence of each partner is actualized through
a commitment of time and resources. Regarding the third suggestion,
section 214(a) of the Act specifies that priority is to be given for
concurrence with the State plan by those organizations listed in
section 213(b)(4) that are required to collaborate in the
development of the application. This section of the Act is a
recognition that system-wide change cannot occur unless the State
officials with the authority and resources for related education and
training programs fully commit to system-wide change. How
effectively local School-to-Work Opportunities programs or
activities are delivered is a consideration in several other
criteria, including Criteria 3, 4, and 6.
Changes: None.
Additional Priority Points [2]--Paid, High Quality Work-Based Learning
Difficulty of Rural States in Meeting Priority
Comment: Several commenters were concerned that this section
would favor urban, industrialized States over rural non-
industrialized States because the former have greater numbers of
employers able to provide paid work experiences. While one commenter
agreed with placing some emphasis on paid, high-quality work-based
learning, most of these commenters pointed out that rural States
have limited access to employers due to factors such as geographic
isolation, predominance of small businesses, and a smaller base of
non-hazardous industry. Two commenters noted that the Act describes
paid work experience as a preferred, but not mandatory, activity of
School-to-Work Opportunities systems, indicating that a ten-point
priority for this factor exceeds the intent of the law. Other
commenters noted that many rural School-to-Work Opportunities
systems will rely mainly on school-sponsored enterprises, school-
based simulations and unpaid work-based learning, and that students
also benefit from these experiences. One commenter suggested that
more information be provided in this section on what constitutes
high-quality work-based learning. One commenter suggested that
points be reduced under this section, and additional points be
awarded for rural School-to-Work strategies under Criterion 3.
Discussion: The Departments are committed to a fair and
equitable review of all applications, and recognize that, in order
to be successful, a School-to-Work Opportunities system must take
into account the unique needs and conditions of the State by which
it has been designed. The Departments agree that unpaid work
experiences and alternatives such as school-sponsored enterprises
are highly valuable in providing students with the opportunity to
gain and apply skills. This priority does not require paid work
experience for every student, but emphasizes paid work experience in
the work-based learning component, and rewards applications which
demonstrate innovative strategies and high levels of effort in this
area. The Departments wish to clarify that this section will not
place rural States at a disadvantage, since points awarded will
reflect comprehensiveness in developing the work-based learning
component and attempting to maximize paid work experiences, rather
than the relative number of students involved in paid work
experiences. Reviewers rank each State's application against the
criteria, not against other applications. In assigning points under
this priority, reviewers will consider the quality of an individual
State's plan given what is feasible for that State, as described in
the application. Therefore, the extent to which an application
presents what is possible and appropriate for the State, as well as
the State's level of effort in obtaining paid work experiences and/
or designing high-quality alternatives which are accessible
systemwide, will determine the number of points awarded. Rural
States that present this information thoroughly and convincingly may
score higher in this section than urban States that do not
demonstrate initiative in developing the work-based component.While
the Departments encourage applicants to review section 103(a) of the
Act for a definition of high-quality work-based learning, they do
not believe this definition needs to be restated in the priority.
Changes: None.
Invitation to Comment
30 Day Submission
Comment: Several commenters opposed the Departments' decision to
require States to submit their applications within 30 days of the
publication of the notice of final selection criteria. Generally,
these commenters believed that 60 days, rather than the proposed 30
days, would allow enough time for States to involve and obtain
support from all of the necessary stakeholders in the submission of
the State application. Three commenters added that the proposed
submission time prevents full consultation with regional or local
stakeholders located throughout the State (particularly large
States). Commenters further noted that the proposed 30 day submittal
deadline limits the ability of State educational agencies and others
who may have dissenting comments to provide them, disregards the
fact that May is a difficult time to obtain comments from classroom
teachers, and would nonetheless be unsuccessful in granting awards
prior to the beginning of the 1995 school year.
Discussion: While the Departments understand the requests by
some States for additional time to submit their applications, they
strongly maintain that, as stated in the notice of proposed
criteria, the 30 day submittal time is sufficient for States that
are prepared for comprehensive system implementation. Furthermore,
the involvement of necessary stakeholders in the endorsement of the
State application's key components should either already be
established or be well underway and would not likely be increased
with the addition of 30 days. Lastly, the establishment of the
Departments' State Planning Guide for a Comprehensive System,
distributed shortly after the publication of the proposed criteria,
provided States with an opportunity to evaluate their current
progress and assess the status of all system components.
Changes: None.
[FR Doc. 95-12332 Filed 5-17-95; 2:50 pm]
BILLING CODE 4510-30-M
