Baltimore County Department of Aging - Madigan, Patti

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