Catholic Charities - Ferguson, Sandra

Mr. Thomas M. Dowd, Administrator Office of Policy Development and Research U.S. Department of Labor 200 Constitution Ave., NW - Room N-5641 Washington , DC 20210 Dear Mr. Dowd, I am writing to express concern regarding the proposed changes to the 2006 Older Americans ACT (OAA). First of all the proposed changes do not conform with the primary purpose. This is an not just an employment program but provides community service. It not only helps low income seniors to become self-sufficient but helps non-profit agencies such as schools, libraries, senior centers, meals on wheels and many others who partner with SCSEP and could provide the service that they do without the aide of these valuable citizens. Limiting SCSEP participation for all participants to a maximum of 60 months which means that even our most-in-need participants would only receive one extention after the 48 month life time limitation would present a serious economic hardship on many if not most of the SCSEP participants. The limit of 1300 hours of community service is yet another restriction that would make it difficult meet the needs of many participants and respond to the needs of non- profits and local conditions. These changes do not address the fact that WIA serves very few older workers and without SCSEP they would have no assistance to sustain them until unsubsidzied employment is located or if it is located considering many of the barriers that older workers have to employment. Finally the deadline of October 14th ,2008 to respond or comment is unrealistic. Many persons who will be impacted by these changes are not even aware. More time is needed to reach as many as possible and have them to comment and present their valid concerns. It is necessary that each comment be read, considered and acted upon. The well being of many older Americans is at stake. Sincerely, Sandra B. Ferguson