October 2, 2008
Thomas M. Dowd, Administrator
Office of Policy Development and Research
U.S. Department of Labor
200 Constitution Avenue, NW, Room N-5641
Washington, DC 20210
Subject: RIN 1205 - AB48- Proposed SCSEP Regulations
Dear Mr. Dowd:
As you are aware, the number of Americans age 55 or older will increase by
almost 30 percent by the year 2011 and mature adults will be working well beyond
the traditional age of retirement. The goal of the Baltimore County Department of
Aging is to provide employers and mature jobseekers with the resources needed
to address the changing workforce.
Older workers demonstrate a strong work ethic coupled with an “old fashioned
employer loyalty.” One example of this quality can be found in notes from a
supervisor in our local Department of Health. We have a Senior Community
Service Employment Program (SCSEP) client who is 66 years of age, and
restricted to a wheel chair due to Cerebral Palsy. She attends daily GED classes
in addition to the twenty hours of community service. Her supervisor notes:
Ms. K is an asset to the agency’s operation. The client has expanded computer
skills and enjoys constant challenges and is learning new tasks. In addition, Ms.
K requires less supervision than full time staff and she is an excellent example to
young persons and peers. She displays how persons with disabilities can continue
life long learning while giving back to the community and earn extra income.
In July 2008, the Baltimore County Department of Aging received a $713,295.00
grant from Senior Service America Inc. (SSAI), one of 18 national organizations
that administer the Department of Labor’s (DOL) Senior Community Service
Employment Program.
This fiscal year in Baltimore County, the SCSEP grant will enable us to enroll
approximately 138 eligible individuals. Additionally, we work together with 64
government and non-profit organizations to offer employment opportunities, which
provide training and economic self-sufficiency. Our clients come to us with many
diverse needs and barriers to employment that may include one or more of the
following: displaced employment, no transportation, loss of a loved one, social
isolation, homelessness, language barriers, lack of education, adult literacy,
disabilities and criminal convictions. The common factor in our clients is the need
and longing to be productive citizens. Our fifty-five plus job seekers are engaged
in the community providing community service while seeking gainful employment.
Mr. S is a typical client who contacted our office after being asked to resign due to
missed time and medical appointments. Mr. S explained he is a Vietnam Veteran
who is fortunate enough to have medical insurance. The Veterans Administration
Hospital schedule is extremely busy and if an appointment is missed, it may take
months to reschedule. So, following emergency gall bladder, coronary artery
disease, heart stint and appendix surgeries, he was asked to resign from his full
time position. After denial of unemployment benefits, he was reminded that he
was terminated for missing time and not medical issues. Mr. S applied for
emergency assistance from his local social service office. After being denied
benefits, Mr. S sought clarification from his caseworker. Still confused, he
pleaded to enroll in the SCSEP Program to avoid eviction from his home. Without
our minimum wage program, his current income would be zero.
I would like to note concerns regarding the proposed regulations that do not
conform to the 2006 Older Americans Act (OAA). If approved, SCSEP’s capacity
to serve communities and older persons most in need, especially from minority
and rural communities, will be greatly reduced. Our concerns include the following:
Ø The 2006 OAA describes community service employment not only as a
job training activity but also as a way to strengthen “self-sufficiency”—not limited
specifically to economic self-sufficiency, but including their emotional and social
well being. SCSEP funds are to be used to provide community service, training
and employment opportunities. The OAA does not state that employment
opportunities supersede community service training.
Ø While we strive to meet and exceed measurable outcomes established
for this program’s success, we have a major concern that if participants who are
continuing to benefit from SCSEP participation are terminated involuntarily, the
vast majority will not find any other employment and training program available to
assist them in their community. According to DOL’s Federal Research and
Evaluation Database, less than 5,000 low-income adults 55 and over exited from
all Workforce Investment Act (WIA) programs in FY2006 across the country.
Limiting terms of extension to the 48-month program diminishes service to clients
and unnecessarily restricts the SCSEP grantee’s capacity to meet the needs of
individual participants and to respond to local conditions. The Baltimore County
Department of Aging suggests flexibility in the policy implementation.
In conclusion, the Baltimore County Department of Aging would like to extend our
plea in requesting that more time is needed to study the proposed regulations and
determine their potential impact on various stakeholders. As these are difficult
economic times, we need to work with a diverse community to seek input about
the proposed regulations and the direct impact in our communities.
We are honored and proud to execute this community service employment
program. Our agency is certain that our mutual goal is to minimize a negative
impact on our participants and our partners. We are deeply committed to not
losing sight of servicing clients and communities most in need.
Thank you for your continued interest and commitment to older adults.
Respectfully yours,
Arnold J. Eppel, Director
Baltimore County Department of Aging
www.takingcareofmomanddad.net
Attachments:
Baltimore County Department of Aging - Madigan, Patti
Title: Baltimore County Department of Aging - Madigan, Patti
Baltimore County Department of Aging - Madigan, Patti
This is comment on Proposed Rule
Senior Community Service Employment Program; Notice of Proposed Rulemaking
View Comment
Attachments:
Baltimore County Department of Aging - Madigan, Patti
Title:
Baltimore County Department of Aging - Madigan, Patti
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