> 800 Wisconsin Street • Unit 88 • Eau Claire, WI 54703-3612

September 29, 2008

Thomas M. Dowd, Administrator

Office of Policy Development and Research

U.S. Department of Labor

200 Constitution Avenue NW, Room N--5641

Washington, D.C. 20210

SUBJECT: RIN 1205--AB48 -- Proposed SCSEP Regulations

Dear Mr. Dowd,

On behalf of the Board of Directors of Senior Citizens Employment &
Training, Inc. (SCET), I am writing this letter to voice our deep
concern about the proposed Notice of Rule Making (NPRM) dated August 14,
2008.

SCET is a small non-profit agency that has provided services to older
job seekers since 1976. We provide training through community based
organizations in six counties in West Central Wisconsin; many of which
are located in small rural communities. Our agency has collaborated with
local government and Senior Service America, Inc. (national contractor
for Title V-Older Americans Act), to provide services to thousands of
low income residents for over 32 years. We believe disadvantaged job
seekers and communities as a whole will be adversely affected if the
proposed regulations are approved. We have listed our concerns below:

**The proposed regulations do not conform to the 2006 Older Americans
Act (OAA).** We believe that in Section 516 of the Older Americans Act
(OAA) of 2006 "the Sense of Congress" establishes community service as
SCSEP's primary purpose, followed by job placement. The second part of
section 516 describes that Congress intends for SCSEP participants to be
placed in subsidized community services jobs which provides "much-needed
support to organizations" and "strengthens the communities that are
served by such organizations." Nonprofit agencies have proven over the
years to provide an excellent environment for training in a safe and
non-threatening workplace for our SCSEP trainees. The individualized
training provided has helped many job seekers gain skills, build their
self esteem and secure the ultimate goal of finding work. With the
downturn in today's economy non profit agencies also struggle to keep up
with the increased demand for their services; the SCSEP has provided
staffing resources to these community based organizations to help them
serve residents in need. Our ability to provide quality services, while
exceeding all goals set forth by the DOL and our national contractor
(including job placement), has been achieved through the partnerships
forged with our community service agencies.

> An excellent example of the importance of community service in rural
> Wisconsin is in Taylor County in the northern part of the state where
> unemployment has risen as high as 10% in the past year. The SCSEP has
> been invaluable in helping the residents of this remote community.
> Rich in natural resources, this community utilizes the Chequamegon
> Forest as a means of attracting tourists that contribute financially
> to this community. SCSEP participants train with the US Forest Service
> to help maintain the land for recreation and the Ranger
> Station/Visitors Center. This community also has had a high number of
> manufacturing jobs and now suffers from excessive layoffs due to lack
> of construction work. The community service aspect of SCSEP is even
> more important as the demand on food pantries, shelters and other
> social service organizations has increased.
>
> **The proposed regulations fail to strengthen the coordination that is
> required between SCSEP and other federal programs, including other OAA
> programs.**
>
> Residents of rural communities, especially elderly, face challenges
> with long distance travel compounded with the high cost of fuel and
> often times lack access to public transit. Participants training in
> the SCSEP with County Aging offices make it possible for elderly to be
> transported to the congregate meal sites for dinner and socialization;
> both important to emotional and physical well-being. Such services
> make it possible for this population to remain independent in their
> homes/family farmstead. Community service employment supports self
> sufficiency in both the job seeker and the community at large. The
> newly created Aging and Disability Resource Centers and their Care
> Management Organizations lack the experience in providing employment
> and training services for their consumers. Our agency receives
> referrals from these providers when an elderly client chooses
> employment as a goal in their plan to maintain their independence. In
> order for us to best serve these individuals and develop their
> employment plan, we must coordinate services with these OAA programs
> to serve elderly who are sometimes frail and/or disabled.
>
> **Limiting SCSEP participation to a maximum of 60 months for all
> participants is contrary to Congressional intent and counterproductive
> to assisting the most vulnerable older adults.** In the 2006 OAA
> Congress did not place an absolute time limit for participants in the
> SCSEP. The proposed regulation 641.570 establishes (for approved
> individuals) a 12-month, once-in-a-lifetime extension to the 48-month
> limit on SCSEP participation. If this policy is implemented, once a
> SCSEP participant exhausts their 60 months on the program they have no
> other employment and training program to fall back on. Our staff has
> been successful in providing high-quality services while exceeding all
> goals set by the US DOL. We recognize that each job seeker we enroll
> has unique barriers to finding work and that some are capable of
> learning faster than others depending on their individual
> circumstances. This proposed regulation will ultimately force
> participants to exit the program regardless if they are ready or not.
>
> **The proposed regulation 641.577, which limits participants to 1300
> hours of community service employment, is another example of an
> unnecessary restriction on a SCSEP.** This limitation forces SCSEP
> providers to treat participants as "one size fits all". The
> backgrounds, life challenges and other circumstances are different for
> each individual that seeks our services. Some individuals may require
> more than 1300 hours of community service experience especially since
> the DOL has implemented a lifetime limit on the number of months one
> can remain on the SCSEP. We recommend that DOL drop this 1300 hour
> limitation on Community service employment.
>
> **The proposed regulations fail to address the main reasons why the
> Workforce Investment Act (WIA) serves very few older persons.** One of
> the most important aspects in providing services to job seekers and
> ensuring positive outcomes is to provide them with information and
> referral to other resources/agencies that also maximize funds. In the
> past 15 years [very]{.underline} [few]{.underline} of our SCSEP
> participants have succeeded in obtaining [any level]{.underline} of
> service from the WIA program. This was concurred in a recent GAO
> report (GAO-03-350 and GAO-08-548) stating the current WIA performance
> measures serve as disincentives for One-Stops to serve significant
> numbers of older persons. Furthermore, the State of WI has shifted
> from "One-Stop" Job Centers to a "Virtual Job Center". This has
> resulted in a reduction, and in some areas, elimination of staff in
> Job Centers. This has had a negative impact especially on residents in
> rural communities who already struggle with high gasoline prices and
> the lack of formal transit. We recommend that DOL postpone all
> proposed new and revised SCSEP regulations related to WIA coordination
> pending reauthorization of WIA as mentioned in the NPRM. We also ask
> that DOL carefully re-examine their regulations that align SCSEP with
> WIA and the present lack of coordination with other Older American Act
> programs.
>
> Sincerely,
>
> Ted Fischer, President
>
> Senior Citizens Employment & Training, Inc.