Senior Service America, Inc. (Sarmiento)

Senior Service America would like to provide the following additional comments related to the Interim Final Rule on SCSEP performance accountability measures (separate and in addition to our comments submitted jointly with other SCSEP national grantees). We have reviewed the comments submitted and sent to us by Experience Works, the largest SCSEP national grantee, and wish to add our support for their third and fourth key areas of concern, namely: ?3) The Department?s ?common measures? are limited in providing full evidence of SCSEP performance,? and ?4) In its current form, this Interim Rule may lead to unintended consequences for SCSEP and to inconsistencies with Congressional intent.? We strongly concur with these concerns as stated in Ms. Cynthia Metzler?s letter to Ms. Maria Kniesler Flynn dated August 27, 2007. The 2006 OAA Amendments added several new definitions and requirements to SCSEP that, when taken together, sharply differentiate SCSEP from all other federally-funded employment and training programs, including WIA. The term ?community service employment? was defined for the first time in section 518(a)(2). No other federal program specifically refers to community service employment as an allowable activity. In addition, for the first time the OAA requires SCSEP grantees to comply with an ?average participation cap for eligible individuals? in section 502(b)(1)(C) and a maximum aggregate period of participation for individual participants in section 518(a)(3)(B). The meaning and effect of these new time-based requirements, while not addressed in the Interim Final Rule, are directly tied to the SCSEP performance accountability measures, especially the ?Entry IntoUnsubsidized Employment Rate? indicator. There is insufficient data to determine how these new time-based requirements will interact with the common measures. In conclusion, we support an ongoing review of the definition and implementation of the SCSEP performance accountability measures as the Department carries out its plan to issue a separate Notice of Proposed Rulemaking to implement additional changes to the SCSEP regulations necessitated by the 2006 OAA Amendments.