Comment on FR Doc # 2010-13870

A significant issue of concern is the fluctating grant amounts from year-to-year, especially when grant reductions occur. As we use our grant almost exclusively for paying salaries and benefits for our DVOP/LVER personnel, even small fluctuations make it very difficult to adminster the program. For instance, a state that realizes a funding reduction (however great or small), may be forced into a situation where the funding is insufficient to cover existing DVOP/LVER personnel costs. This is the most frustrating situation, as we simply cannot release employees on short notice without cause, from year-to-year. At the other end of the spectrum is the situation where, under the current funding formula approach, a state with a growing population of veterans receives additional funding through the grant. The state may encounter state-imposed hiring freezes or other constraints and problems that make it impossible to use the entire funded amount. The end result is that some states have money they cannot spend and others do not get the funding they need to provide basic services as intended by the program. Moreover, even if we could hire and release without obstruction it is difficult to believe we could attract the quality of worker desired to serve our veterans not to mention the increased cost to train the workers. As I understand the current funding formula methodology, a statistically invalid sample is used when establishing funding levels for the states, making those funding levels suspect. With many individuals including veterans moving from state to state, the number of new veterans leaving the military (as many as 250,000 per year) and the number of national guardsmen and reservists being called to active duty, it becomes nearly impossible to accurately estimate the total number of veterans in any given state. How many of these new and mobile veterans are actually seeking employment is equally difficult to determine without gathering a vast amount of data. Additionally and related is the fact that some states are simply larger, geographically speaking. These states have veterans located in both rural and urban locations and while the number of veterans in the rural areas may be relatively small, we believe it is still important to serve them with same quality of service provided to veterans elsewhere. However, it is neither effective nor efficient to try to provide services to those veterans with DVOP/LVER personnel that must travel great distances. Therefore, for the sake of providing quality and timely services to our veterans in those rural areas, it is imperative that we have DVOP/LVER personnel assigned in those locations. Normally, these workers are half-time. When applying the funding formula, such geographic dispersion and distances must be considered. Bottom line, a funding formula should include criterion that take into account the number of veterans actually receiving services from the workforce agency and not an unsupportable figure based on an invalid survey. Funding should also consider the performance achieved by each state. We have found in recent years that our reward for high performance has been the occasional reduction in funding. Geographic size of each state must be considered. In this regard, DVETs should be relied upon to make determinations and input regarding the minimum number of DVOP/LVER personnel that are required to operate the VETS program as intended and desired within their respective states.