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Performance Partnership Pilots for Disconnected Youth: First Annual Report to Congress 

June 2017 

The report (S. Rept. 114-74) accompanying S.1695 (titled “Departments of Labor, Health and 

Human Services, and Education, and Related Agencies Appropriations Act, 2016”), passed by 

the Senate Committee on Appropriations, requested annual reports containing information about 

the Performance Partnership Pilots for Disconnected Youth (P3) program. Specifically, the 

Senate report requested “annual reports containing the following information: a detailed 

summary of all involved pilot programs, an overview of how pilots were selected, a summary of 

findings from the various pilots, and recommendations for Congress on how to apply best 

practices more broadly.”

Because the pilots are still in the early stages of implementation, we have limited information 

regarding findings from individual pilots or recommendations regarding best practices and 

opportunities for broader application. This annual report, the first prepared in response to this 

request, provides detailed information about the P3 program, including descriptions of the 

individual pilots and how they were selected, and identifies questions and considerations that 

highlight preliminary lessons from the P3 program. Additional detail is included as appendices. 

As implementation of the pilots continues and the evaluation findings become available, we will 

gain a more complete understanding of the P3 program, including the outcomes achieved by 

individual pilots, and the strengths and limitations of the P3 program model, which we intend to 

continue sharing with Congress and the public. 

Overview

P3 offers a unique opportunity to test innovative, cost-effective, and outcome-focused strategies 

for improving results for disconnected youth, and may also offer broader lessons regarding ways 

in which various federal grant programs can enable improved outcomes by allowing greater 

flexibility for grantees. According to the U.S. Census Bureau, more than 5 million 14-to-24- 

year olds in the United States are not on a clear path to postsecondary education or training and a 

rewarding career. They are neither working nor in school and, in many cases, face the additional 

challenges of being homeless, in foster care, or involved in the justice system. Often 

disconnected from their families and valuable social networks, these young people struggle to 

make successful transitions to adulthood and to reach the educational and employment 

milestones critical to escaping a lifetime of poverty. The P3 authority provides States and local 

and tribal governments greater freedom to innovate in order to serve these youth, providing an 

opportunity to request waivers of programmatic requirements that appear to impede effective 

service delivery. 

Congress authorized the inclusion of funds from fiscal years 2014, 2015, and 2016, and 

authorized the selection of up to 10 pilots for each of those years. Federal agencies solicited 

applications for these three rounds of pilots and received 45 eligible applications across the 3 

years. Applications were assessed and scored by peer reviewers using selection criteria 

published in the notices inviting applications. To date, nine pilots (Round 1) have been 

authorized, while another seven entities (Rounds 2 and 3) have been designated pilot finalists 
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with which the Federal agencies are currently negotiating performance agreements. 

Descriptions of the pilots’ and pilot finalists’ projects appear in Appendix A. 

Implementation of the Fiscal Year 2014 Authority (Round 1)

Enacted on January 17, 2014, the Consolidated Appropriations Act, 2014 (Public Law 113-76) 

(the 2014 Act) authorized the Departments of Education (ED), Labor (DOL), and Health and 

Human Services (HHS), along with the Corporation for National and Community Service 

(CNCS) and the Institute of Museum and Library Services (IMLS) (the Agencies), to enter into 

performance partnership agreements that give State, local, and tribal governments greater 

flexibility in using funds awarded under two or more discretionary programs administered by the 

Agencies. The 2014 Act authorized the Agencies to enter into up to 10 performance partnership 

agreements. 

States, localities, and tribes that entered into P3 agreements were authorized to request waivers 

for requirements related to certain discretionary funds, including both formula and competitive 

grant funds, from the Agencies in order to implement strategies to improve outcomes for 

disconnected youth. The 2014 Act states that “‘[t]o improve outcomes for disconnected youth’ 

means to increase the rate at which individuals between the ages of 14 and 24 (who are lowincome and either homeless, in foster care, involved in the juvenile justice system, unemployed, 

or not enrolled in or at risk of dropping out of an educational institution) achieve success in 

meeting educational, employment, or other key goals.” This waiver authority provided the 

authority to blend discretionary funding. 

The 2014 Act states that heads of the Agencies may not only exercise any existing waiver 

authority but also may waive any statutory, regulatory, or administrative requirement that they 

are otherwise not authorized to waive, as long as the waiver is in keeping with important 

safeguards. Some of these safeguards include that waivers must be consistent with the statutory 

purposes of the respective Federal programs contributing funds to the pilot and necessary to 

achieve the pilot’s outcomes. In addition, the heads of the Agencies must determine that the 

waivers and the proposed use of program funds: (1) will not result in denying or restricting 

individual eligibility for services funded by those programs, and (2) will not adversely affect 

vulnerable populations that are the recipients of those services. Moreover, the Agencies may not 

waive requirements related to nondiscrimination, wage and labor standards, or allocation of 

funds to State and substate levels. 

Consultation with the Field

The Agencies have considered public input critical to both the development and the effective 

implementation of the P3 authority. Anticipating P3 authority, in June 2012, ED published a 

Request for Information on Disconnected Youth in the Federal Register (77 FR 32959) (RFI) 

seeking public input regarding the implementation of the potential P3 statutory authority, which 

was first proposed by in the FY 2013 budget request. The 171 comments ED received in 

response to the RFI emphasized the need for greater flexibility, highlighted promising initiatives, 

and offered recommendations for effectively serving disconnected youth and administering P3. 

The responses informed the Agencies’ thinking about how best to implement the P3 authority 

when it was enacted into law in FY 2014. 
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On April 28, 2014, the Agencies issued a consultation paper, Changing the Odds for 

Disconnected Youth: Initial Design Considerations for Performance Partnership Pilots, that 

provided background information about the pilot authority and described the Agencies’ initial 

thinking about the implementation of the authority.1 The paper also encouraged stakeholders to 

respond by email to key questions about implementing P3 pilots. The Agencies used their 

research and analysis for the paper to guide two joint national webinars hosted by HHS on April 

21 and 30, 2014, that provided information to the field and solicited feedback about the 

implementation of the authority.

In addition, on July 31, 2014, ED published a notice in the Federal Register that invited public 

comment on the application process for P3 (79 FR 44436). ED sought comments on the 

following three questions: 

• What information, in addition to the information required by the Act, should entities be 

required to submit in their applications? 

• What criteria should the Agencies use to evaluate applications? 

• What technical assistance would be helpful to entities in preparing their applications?

ED received eight responses to the notice that made various recommendations with respect to the 

pilot application requirements and process. These recommendations informed the Agencies’ 

development of the application process. For example, one respondent recommended that 

applicants provide a logic model, while another recommended that the Agencies give priority to 

projects that are likely to achieve significant improvements in the outcomes of disconnected 

youth and projects that will replicate evidence-based approaches. 

Round 1 Notice Inviting Applications (FY 2014) 

The Office of Management and Budget (OMB) designated ED as the lead Federal agency 

responsible in FY 2014 for soliciting applications and managing the P3 initiative on behalf of the 

Agencies. 

ED published a notice inviting applications in the Federal Register on November 24, 2014 (79 

FR 70033) (Round 1 notice) that described how pilots would be selected for the first P3 

competition. The notice included three absolute priorities, which, for the purposes of the first 

round P3 competition, created separate categories for scoring and considering applications. The 

Agencies included these absolute priorities to test the theory of action underlying the P3 

authority in a variety of settings. These absolute priorities were: 

• Absolute Priority 1—Improving Outcomes for Disconnected Youth. Under this priority, 

we considered applications that proposed pilots that were designed to improve outcomes 

for disconnected youth who resided in communities that were not included in Absolute 

Priorities 2 and 3. 

 

1 Available at: http://youth.gov/docs/P3_Consultation_Paper_508.pdf. 
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• Absolute Priority 2—Improving Outcomes for Disconnected Youth in Rural 

Communities. Under this priority, we considered applications that proposed to improve 

outcomes for disconnected youth in one or more rural communities only. 

• Absolute Priority 3—Improving Outcomes for Disconnected Youth in Tribal 

Communities. Under this priority, we considered applications from a partnership that 

included one or more Indian tribes that proposed to improve outcomes for disconnected 

youth in one or more Indian tribes. 

The Round 1 notice also included three competitive preference priorities that awarded additional 

points to applications that met certain requirements. The first two priorities awarded additional 

points to applicants that proposed to implement an independent evaluation of their projects, 

while the third awarded additional points linked to select local communities. Under Competitive 

Preference Priority 1, up to 5 additional points were available for applicants that proposed to 

carry out an independent evaluation that used a quasi-experimental design, while 10 additional 

points were available under Competitive Preference Priority 2 to applicants that proposed to 

carry out an independent evaluation that was a randomized controlled trial. Applicants’ 

evaluation proposals were scored based on the clarity and feasibility of the proposed evaluation 

design and the applicants’ demonstrated expertise in planning and conducting a study that used a 

quasi-experimental design or that was a randomized controlled trial. The third competitive 

preference priority awarded two points to projects that were designed to serve and coordinate 

with a Federally designated Promise Zone.

Additionally, the Agencies made available to the FY 2014 P3 pilots start-up grants of up to 

$700,000 each to support ongoing planning, streamlined governance, strengthened data 

infrastructure, improved coordination, and related activities to help pilots improve outcomes for 

disconnected youth.

Applicants were given 100 days to submit applications. To promote the opportunity and provide 

technical assistance to prospective applicants, the Agencies held two webinars that were hosted 

by DOL. The first webinar focused on the notice inviting applications, and the second provided 

technical assistance to prospective applicants that were considering proposing independent 

evaluations. These webinars were viewed collectively by 777 individuals. The Agencies also 

published answers to frequently asked questions about the notice and the pilot authority at 

www.youth.gov/P3 and updated the guidance as needed throughout the application period. 

ED received 27 eligible applications in response to the Round 1 notice. Using the selection 

criteria published in the notice, Federal staff from the Agencies, as well as from the U.S. 

Department of Agriculture and the U.S. Department of Housing and Urban Development, with 

expertise in areas relevant to P3, such as dropout prevention, intervention, and re-engagement 

and improving employment outcomes for vulnerable youth and young adult populations, 

reviewed and scored these 27 applications. The selection criteria addressed: (1) the need for the 

project (up to 5 points); (2) the need for requested flexibility, including blending of funds and 

other waivers (up to 10 points); (3) project design (up to 25 points); (4) work plan and project 

management (up to 10 points); (5) partnership capacity (up to 15 points); (6) data capacity (up to 

30 points); and (7) budget and budget narrative (up to 5 points). In addition, reviewers who had 
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expertise in research and evaluation scored Competitive Preference Priorities 1 and 2, the two 

priorities for independent evaluations. 

Following this review, the Agencies reviewed the top-ranked applications and the waivers they 

sought to determine whether they could be granted under the P3 authority or existing waiver 

authority, whether the inclusion of a program or particular waiver would be consistent with other 

significant legal or policy considerations, and whether the waiver was needed. To clarify their 

waiver requests, the top-ranked applicants were asked to respond in writing to Agency questions 

and to participate in one or more telephone conference calls. The Agencies selected nine 

applicants to be finalists for Round 1 pilots. On September 30, 2015, ED awarded $6,154,998 in 

start-up funds to these nine applicants, but conditioned their access to these funds on their 

signing a final performance agreement with the Agencies that administered programs included in 

the project. Abstracts of the nine projects appear in Appendix A.

The Agencies then proceeded to negotiate performance agreements with the nine entities. 

Section 526(c)(2) of Division H of the 2014 Act specifies the contents of these agreements. 

The 2014 Act indicated that each agreement must include: 

• The length of the agreement, which could extend to September 30, 2018; 

• The Federal programs and Federally funded services that are involved in the pilot; 

• The Federal discretionary funds that are being used in the pilot and the period of 

availability for the obligation of such funds; 

• The non‐Federal funds that are involved in the pilot, by source (which may include 

private funds as well as governmental funds) and by amount; 

• The State, local, or tribal programs that are involved in the pilot; 

• The populations to be served by the pilot;

• The cost‐effective Federal oversight procedures that will be used for the purpose of 

maintaining the necessary level of accountability for the use of the Federal discretionary 

funds; 

• The cost‐effective State, local, or tribal oversight procedures that will be used for the 

purpose of maintaining the necessary level of accountability for the use of the Federal 

discretionary funds; 

• The outcome (or outcomes) that the pilot is designed to achieve; 

• The appropriate, reliable, and objective outcome‐measurement methodology that will be 

used to determine whether the pilot is achieving, and has achieved, specified outcomes; 

• The statutory, regulatory, or administrative requirements related to Federal mandatory 

programs that are barriers to achieving improved outcomes of the pilot; and 

• Criteria for determining when a pilot is not achieving the specified outcomes that it is 

designed to achieve and subsequent steps, including: (1) the consequences that will 

result; and (2) the corrective actions that will be taken in order to increase the likelihood 

that the pilot will achieve such specified outcomes. 

Implementation of the Fiscal Year 2015 Authority (Round 2) 

ED continued to be the lead Federal agency responsible in FY 2015 for soliciting applications 

and managing the P3 initiative on behalf of the Agencies.
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Notice of Proposed Priorities 

The Consolidated and Further Continuing Appropriations Act, 2015 (Public Law 113-235) (the 

2015 Act) extended the P3 authority to provide for up to 10 additional pilots and allow for the 

inclusion of certain funds from the Department of Justice. To implement this authority and 

solicit public comment, on October 22, 2015, ED published on behalf of the Agencies a notice of 

proposed priorities, requirements, definitions, and selection criteria (NPP) in the Federal 

Register (80 FR 63975). The priorities, requirements, definitions, and selection criteria proposed 

in this notice were based largely on the priorities, requirements, definitions, and selection criteria 

that were used in the November 2014 notice inviting applications for Round 1. For example, as 

in the November 2014 notice, the NPP proposed priorities for projects that serve disconnected 

youth in rural, tribal, and other communities. One of the lessons learned in Round 1 was that the 

use of absolute priorities promoted greater diversity in pilot settings than might otherwise have 

been achieved. In Round 1, the Agencies selected one project that proposed to serve a rural 

community (Eastern Kentucky Concentrated Employment Programs) and one project submitted 

by a partnership led by an Indian tribe that proposed to serve disconnected youth in an Indian 

tribe (Ysleta del Sur Pueblo). However, the Round 1 notice and the NPP documents differed in 

several other important respects:

• Additional Priorities for High-Need Subpopulations. The NPP also proposed additional 

priorities that focused on high-need subpopulations of disconnected youth, including 

priorities for disconnected youth who are unemployed and not enrolled in education, 

English learners, individuals with disabilities, homeless, in foster care, involved with the 

justice system, and refugees or other immigrants. In Round 1, the Agencies learned that 

State, local, and tribal governments may need additional incentives to focus their P3 

projects on a variety of high-need subpopulations of youth. Most of the 27 applications 

that were submitted in Round 1 focused on disconnected youth who were at risk of 

dropping out of an educational institution. As a result, the Agencies proposed these 

additional priorities to create a means of providing incentives to applicants to serve the 

most vulnerable populations of disconnected youth.

• Priority for Work-Based Learning. In addition, the NPP proposed a priority for projects 

that provide paid work-based learning opportunities, including opportunities that are 

offered during the summer months, which are integrated with academic and technical 

instruction. As indicated in the NPP, the Agencies proposed this priority because the 

employment rate among youth has declined precipitously over the last decade, and 

addressing the employment needs of disconnected youth is critical to improving their 

well-being and preparation for lives as productive adults. 

• A Single Priority for Evaluation. The NPP proposed to establish a single priority for 

projects that would support evaluations that use either a randomized controlled trial or a 

quasi-experimental design, rather than two separate priorities for these two kinds of 

evaluations as the notice inviting applications for the first Round of P3 had done. 

Applicants’ proposed evaluation plans would be evaluated based on the quality of the 

proposed evaluation’s design, appropriateness of the design to best capture key pilot 

outcomes, the scale of the contribution the evaluation will make to the evidence base, and 

the applicant’s expertise in planning and conducting comparable studies. 
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• Streamlined Application Requirements. To reduce burden on applicants and facilitate the 

review process, the NPP proposed to eliminate or streamline several of the application 

requirements. During their review of the applications in Round 1, the Agencies 

determined that some of the information applicants were required to submit could be 

streamlined or simplified to reduce burden on applicants, as well as to facilitate the 

timely review of applications by reviewers. Additionally, the NPP proposed to collect 

some of this information in table form to make clearer to applicants all of the data they 

must provide in their applications and to simplify how applicants provide these data. 

• Simplified Selection Criteria. The NPP also proposed streamlined and simplified

selection criteria to reduce burden on applicants, as well as to improve their focus on the 

factors that the Agencies consider to be most critical to the successful implementation of 

pilots.

Eleven parties submitted comments in response to the NPP. A key theme of the comments was 

concern that the FY 2014 selection process for pilots was too complicated. Generally, 

respondents encouraged the Agencies to streamline further the application requirements and 

simplify the review process. Some respondents encouraged the Agencies to direct or encourage 

applicants to focus on youth with the greatest needs and recommended additional priorities (e.g., 

applicants proposing to serve disconnected youth who are parents, applicants proposing to serve 

urban communities that have experienced violent protests) and supported additional priorities 

that were proposed (e.g., immigrant or refugees, English learners, homeless youth). 

Other commenters were concerned that introducing new priorities in the competition under the 

FY 2015 authority would further complicate the process. 

Notice of Final Priorities

On behalf of the Agencies, ED published a notice of final priorities, requirements, definitions, 

and selection criteria (NFP) in the Federal Register on April 28, 2016 (81 FR 25339). In 

response to public comment, the NFP reduced burden on applicants by removing several 

application requirements that had been proposed in the NPP. The NFP also revised the priority 

for disconnected youth who are unemployed and out-of-school to limit it to those youth who face 

significant barriers to accessing education and employment. Additionally, the NFP revised the 

priorities for projects designed to improve outcomes for subpopulations of high-need 

disconnected youth (i.e., youth who are unemployed and out of school, youth who are English 

Learners (ELs), youth with a disability, homeless youth, youth in foster care, youth involved in 

the justice system, and youth who are immigrants or refugees) to specify that, in order to meet 

the priority, a project must serve the particular subpopulation identified in the priority and also 

be likely to result in significantly better educational or employment outcomes for the 

subpopulation. Finally, in response to a public comment, the NFP established an additional 

priority for projects that serve youth who are pregnant or parenting and that are likely to result in 

significantly better educational or employment outcomes for such youth. 
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Round 2 Notice Inviting Applications (FY 2015) 

On behalf of the Agencies, ED published a notice inviting applications (NIA) in the Federal 

Register on April 26, 2016, (81 FR 24573) for FY 2015 (Round 2 notice). 

The Round 2 notice included four absolute priorities, which, for the purposes of the second 

round of P3 competition, created separate categories for scoring and considering applications:

• Absolute Priority 1—Improving Outcomes for Disconnected Youth. Under this priority, 

the Agencies considered applications that were designed to improve the outcomes of 

disconnected youth who reside in communities that are not included in Absolute 

Priorities 2, 3, or 4. 

• Absolute Priority 2—Improving Outcomes for Disconnected Youth in Rural 

Communities. Under this priority, the Agencies considered applications that were

designed to improve the outcomes of disconnected youth in one or more rural 

communities only. 

• Absolute Priority 3—Improving Outcomes for Disconnected Youth in Tribal 

Communities. Under this priority, the Agencies considered applications from a 

partnership that included one or more Indian tribes that were designed to improve the 

outcomes of disconnected youth in one or more Indian tribes. 

• Absolute Priority 4—Improving Outcomes for Disconnected Youth in Communities that 

Have Recently Experienced Civil Unrest. Consistent with language that Congress added 

in the Consolidated Appropriations Act, 2016 (Public Law 114-113) (the 2016 Act), 

under this priority, the Agencies considered applications that were designed to improve 

outcomes for disconnected youth in one or more communities that have recently 

experienced civil unrest. The notice indicated that, though the economy has recovered 

strongly in many places, many communities continue to struggle with high youth 

unemployment, low graduation rates, and crime. The notice stated that these and other 

continuing challenges can manifest in different instances of civil unrest, such as large 

protests or instances of civil disobedience, increases in self-directed or interpersonal 

violence in concentrated areas, or civic disorder prompted by a public health emergency. 

The Round 2 notice also included four competitive preference priorities that allowed applicants 

to receive extra points for satisfying certain criteria:

• Competitive Preference Priority 1 awarded up to five additional points for projects that 

proposed to serve those disconnected youth who are neither employed nor enrolled in 

education and who also face significant barriers to accessing education and employment 

and that are likely to result in significantly better educational or employment outcomes 

for such youth. 

• Competitive Preference Priority 2 awarded three additional points to projects that 

proposed to provide all disconnected youth it serves with paid work-based learning 

opportunities. 
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• Competitive Preference Priority 3 awarded two additional points to projects that were

designed to serve and coordinate with a Federally designated Promise Zone. 

• Competitive Preference Priority 4 awarded up to an additional 10 points to applications 

that proposed to conduct an independent evaluation of the impacts on disconnected youth 

of its overall program or specific components of its program that is a randomized 

controlled trial or a quasi-experimental design study.

Additionally, the Agencies announced that they would make available to the FY 2015 P3 pilots 

start-up grants of up to $350,000 to support ongoing planning, streamlined governance, 

strengthened data infrastructure, improved coordination, and related activities to help pilots 

improve outcomes for disconnected youth. The amount of the start-up grants was reduced based 

on competing priorities for agency funds and on the fact that one of the purposes of P3 is to 

focus on flexibility rather than new funding for the pilot sites. However, maintaining start-up 

grants was important based on feedback from the field in responses to the NPP that indicated that 

the start-up funding plays a critical role in launching and evaluating pilots. 

Applicants were given 60 days to submit applications so that pilot finalists could be selected by 

the end of the fiscal year. To promote the opportunity and provide technical assistance to 

prospective applicants, the Agencies held a webinar on May 9, 2016, that was hosted by HHS. 

The webinar was viewed over 400 times during the first broadcast, and was available online for 

later viewing. The Agencies also published answers to frequently asked questions about the 

notice and the pilot authority at www.youth.gov/P3. 

A number of applications received in response to the round 2 notice were not eligible because 

they did not meet all of the requirements in the notice, including the deadline for the submission 

of applications. To allow applicants additional time to prepare and submit their applications, ED 

reopened the competition on July 12, 2016, for one week to invite and accept additional 

applications. If applicants had submitted ineligible applications, they had time to address the 

issues that made their application ineligible and to submit a revised application. 

In response to the notice reopening the competition, ED received three potentially eligible 

applications. Using the selection criteria published in the first notice, individuals with expertise 

in areas relevant to P3, such as dropout prevention, intervention, and re-engagement and 

improving employment outcomes for vulnerable youth and young adult populations, reviewed

and scored these three applications. In addition, reviewers who had expertise in research and 

evaluation scored Competitive Preference Priority 4, the priority for independent evaluations. 

The Agencies selected one applicant to be a finalist for designation as a Round 2 pilot, Maricopa 

County Education Service Agency in Phoenix, Arizona. On September 30, 2016, ED awarded 

$350,000 in start-up funds to this applicant but conditioned its access to these funds on its 

meeting certain conditions that would allow the agencies to grant the necessary waivers and its 

signing a final performance agreement with ED and DOL, the two agencies that administer 

programs that would be included in the project. An abstract that describes the proposed pilot

appears in Appendix A. 
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Implementation of the Fiscal Year 2016 Authority (Round 3) 

Round 3 Notice Inviting Applications (FY 2016) 

The 2016 Act reauthorized P3, allowing for the creation of up to 10 additional pilots, as well as 

allowing for the inclusion of FY 2016 Homeless Assistance Grants administered by the 

Department of Housing and Urban Development (HUD). On behalf of the Agencies, ED 

published an NIA in the Federal Register on August 15, 2016, (81 FR 54056) for FY 2016 

(Round 3 notice). This notice differed from the Round 2 notice in three respects:

• Homeless Assistance Programs. Consistent with section 242 of Division L of the 2016 

Act, the Round 3 notice permitted applicants to include FY 2016 Homeless Assistance 

Grant programs administered by HUD. These are the Continuum of Care Program and 

the Emergency Solutions Grants Program. 

• Deferred Application Requirements. The Round 2 notice required all applicants to 

include with their applications a memorandum of understanding or letter of commitment

from each partner that described the terms and conditions of its participation in the pilot. 

All applicants for Round 2 also were required to include in their initial application an 

assurance that the State, local, or tribal government(s) with authority to grant any needed 

non-Federal flexibility, including waivers, has approved or will approve such flexibility 

within 60 days of an applicant’s designation as a pilot finalist; or include an assurance 

that non-Federal flexibility, including waivers, is not needed in order to successfully 

implement the pilot. To reduce burden on applicants, the Round 3 notice did not require 

applicants to include these documents in their applications. Instead, these documents 

were requested only from top-scoring applicants following the peer review of 

applications. Top-scoring applicants had 21 days after their notification by ED to submit 

these documents. 

• Longer Application Period. The application period for Round 3 was 75 days, 15 days 

longer than the application period in the Round 2 notice. The deadline for applications 

was October 31, 2016. 

As in Round 2, HHS hosted a webinar for prospective applicants on August 25, 2016. DOL, ED, 

and HHS staff participated in delivering the briefing. Eighty people viewed the live webinar, 

and a recording was viewed almost 600 times. 

In response to the third notice inviting applications, ED received 15 potentially eligible 

applications. (An application is potentially eligible when the applicant meets the basic eligibility 

criteria but the application has not yet been reviewed for meeting all application requirements.) 

Using the selection criteria published in the first notice, individuals with expertise in areas 

relevant to P3, such as dropout prevention, intervention, and re-engagement and improving 

employment outcomes for vulnerable youth and young adult populations, reviewed and scored 

these applications. In addition, reviewers who had expertise in research and evaluation scored 

Competitive Preference Priority 4, the priority for independent evaluations. 
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The Agencies selected six applicants to be finalists for designation as Round 3 pilots. On

January 19, 2017, ED awarded $1,498,172 in start-up funds to these six finalists but conditioned 

their access to these funds on their meeting certain conditions that would allow the agencies to 

grant the necessary waivers and their signing a final performance agreement with the applicable 

agencies. Abstracts that describe the proposed pilots appear in Appendix A. 

National and Site Evaluations 

The primary purpose of a demonstration such as P3 is to learn about new program models. To 

this end, in addition to giving priority to applicants that proposed a rigorous evaluation 

(described above) certain participating agencies were able to allocate resources to support a 

national evaluation. The national evaluation will document the extent to which P3 led to 

increased coordination across agencies and programs in support of greater flexibility for selected

communities to improve outcomes for disconnected youth. The national evaluation also will 

synthesize individual site evaluations and, in doing so, highlight effective and promising 

practices for improving outcomes for disconnected youth. The national evaluation includes: 

• Evaluation Technical Assistance: Rounds 1, 2, and 3 sites and their independent 

evaluators will receive assistance in designing and conducting P3 site evaluations.

• Systems and Process Analysis: Analysis of P3 implementation and processes and 

national program and service delivery systems changes that have resulted from P3. 

Analysis will be based on site visits, interviews, and partner surveys with Round 1 sites, 

and interviews with Federal staff. 

• Collection of Participant Data: Cross-site synthesis of site data and reports to describe 

Round 1 pilots and participant characteristics and outcomes, based on data collected by 

sites. 

• Synthesis of Local Evaluation Reports: Cross-site aggregation and (to the extent 

possible) comparison of Round 1 sites based on sites’ final evaluation reports and data.

The final report will be available in 2020, with interim findings available in 2019. Due to the 

absence of dedicated resources, the national evaluation activity for Rounds 2 and 3 may have to 

be limited to technical assistance to support evaluations conducted by individual sites. The 

national evaluation is being managed by the Department of Labor, and conducted under contract 

by Mathematica Policy Research.

Conclusion: Questions and Considerations

The P3 pilot sites and national evaluations for Round 1 will not have interim findings until 2019 

and final findings until 2020. Given this, it is premature to provide recommendations regarding 

scaling P3 or applying best practices more broadly. Nevertheless, the experiences to date of 

Federal agencies and feedback from pilot sites and applicants suggest a number of questions and 

considerations that may warrant attention. As P3 evolves, new lessons may emerge, and the 

national evaluation will provide a more rigorous assessment of P3 implementation and the 
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success of individual pilots. The below questions and considerations highlight preliminary 

lessons of P3 that may inform Congress when considering future P3 authorization. 

• How can application and appropriations cycles best align? The year-to-year authority to 

conduct P3 makes it difficult for potential applicants to have sufficient time to plan and 

prepare applications while still allowing adequate time for Federal agency review. The 

timing under P3 thus far can present difficulties, as applicants need to reserve funding 

early in the fiscal year to support a potential pilot but do not know whether they have 

been selected as a pilot until late in the fiscal year, or even the following fiscal year. 

Multi-year authority, or an authority that is not dependent on the appropriations cycles, 

would facilitate applications and allow agencies to better plan and implement the 

program, including improvements to the application process requested by applicants. 

Congress may want to consider including such authority in any future P3 authorization. 

• How should the application process be structured? A staged application process may 

better serve applicants, allowing them to submit shorter, preliminary proposals for 

consideration and feedback, including technical assistance discussed below, and allowing 

discussion of whether Federal waivers are required for potential projects. A staged 

process could reduce the burden of applying for P3. Such an application process would 

not necessarily require a modification of statutory language authorizing P3. However, 

because such a process would require a longer application period, the staged process 

would be most feasible if P3 were authorized on a multi-year basis or through an 

authority that is not dependent on the appropriations cycles. 

• What resources and capacity are needed to administer P3? P3 lacks dedicated resources, 

which has limited funding available to support grantee start-up, technical assistance, and 

evaluation. Adequate federal staffing to administer P3 remains a challenge, given the 

complexity of the initiative. A recent Government Accountability Office (GAO) report 

recommended that agencies determine the resources needed to administer P3 in order to 

better plan for completing the current rounds of pilots and identifying the capacity and 

resource implications of scaling P3

• At what stage is technical assistance most valuable? The pilot selection process has 

demonstrated that many applicants would benefit from Federal engagement and technical 

assistance during demonstration planning and prior to application, regarding concept and 

service model, evaluation design, and identifying current barriers and the need for 

potential waivers. Technical assistance has been a cornerstone of pilot progress but has 

occurred during implementation only. It appears that greater technical assistance upfront 

could reduce the need for ongoing technical assistance after pilot selection, and 

potentially result in greater efficiency and stronger pilots. Shifting technical assistance in 

this manner would not necessarily require a modification of the statutory language 

authorizing P3, but the extent to which Federal agencies could provide greater upfront 

technical assistance would be limited by capacity and available resources. 

• How might agencies support applicants not needing P3 waivers in pursuing program 

improvements? Some P3 applicants with promising proposals to improve outcomes have 

been denied because the proposed projects do not require Federal waivers. Some of these 
13

projects may benefit from technical assistance, peer learning, and evaluation. Given this, 

it may make sense to consider how projects that do not require Federal waivers could 

contribute to P3’s broader agenda for improving outcomes. The extent to which Federal 

agencies could do this would be limited by capacity and available resources, but would 

not necessarily require a modification of the statutory language authorizing P3. 
14

APPENDIX A: Pilot Summaries

FY 2014 (Round 1) Pilot Summaries

Pilot Lead: City of Los Angeles (CA)

The City of Los Angeles and core partners including the County of Los Angeles, the Los 

Angeles Unified School District (LAUSD), and the Los Angeles Community College District 

will enhance service systems for disconnected youth. By building on its infrastructure of 16 

YouthSource Centers (YSCs) strategically located in neighborhoods with high dropout rates, as 

well as within the Los Angeles Promise Zone, LA P3 will target youth who are ages 16 through 

24, high school drop-outs, in foster care, homeless, or on probation. Funded with local education 

dollars, funds provided under the youth program authorized by Title I of the Workforce 

Innovation and Opportunity Act (WIOA) and a Workforce Innovation Fund (WIF) grant, the 

YSCs conduct outreach to, and principally serve, disconnected youth. The LAUSD co-locates a 

school counselor at each YSC to provide youth with school re-enrollment assistance and to make 

referrals to school system resources, such as mental health services, and other support services. 

Through LA P3, the City will expand the employment and education services available to youth 

through the YSCs and extend the YSC partnership to include regional areas throughout Los 

Angeles County. The enhanced service model will include Los Angeles County Departments 

such as the Department of Community and Senior Services, Department of Health Services, 

Department of Children and Family Services, Probation Department, Department of Public 

Social Services, the State Employment Development Department, local Cal State Universities 

(CSU5), the Los Angeles LGBT Center, the LA Chamber and many others. The pilot will braid 

the following Federal and Non-Federal funding sources to support services for the disconnected 

youth target population: WIOA Title I Youth and Title I Adult programs, Runaway and 

Homeless Youth Act Transitional Living Program, Promise Neighborhoods, local funding, and 

My Brother’s Keeper (private philanthropy). The project will seek to serve 8,000 youth.

The chart below identifies the waivers the pilot was granted. 

Program Waiver Citation

Transitional Living 

Program (TLP)

Authorize the Los Angeles LGBT Center to

increase the eligibility age from 21 to 24 for 

homeless youth in the TLP. The Los Angeles 

LGBT Center is required to submit a report that 

outlines the number of youth participants by 

age to demonstrate that the number of younger 

youth (ages 16-21) served is not decreased as a 

result of broader eligibility for older youth. 

Runaway and Homeless 

Youth Program 

Authorizing Legislation 

Part B—Transitional 

Living Grant Program 

Sec. 322 Eligibility and 

Sec. 387 Definitions 
15

Program Waiver Citation

Workforce 

Innovation and 

Opportunity Act 

(WIOA) Title I 

Youth 

For funds used as part of the P3 pilot, consider 

foster, homeless, and runaway youth who are in 

school to be counted in the 75 percent out-ofschool youth service category for fiscal 

accounting purposes only. The DOL, 

Employment and Training Administration, 

approved this waiver only for the youth 

participating in the pilot. The waiver addresses 

a fiscal accounting reporting and documentation 

burden. The applicant believes that even if this 

waiver were not granted, it would still meet the 

75 percent out of school service requirement in 

WIOA Section 129(a)(4)(A).

WIOA Sec. 129 

(a)(1)(B)

Consulting Agency2: U.S. Department of Labor 

Participating Agency3: U.S. Department of Health and Human Services

Pilot Lead: Children’s Services Council of Broward County (FL)

The Children’s Services Council of Broward County will blend funding under the Workforce 

Innovation and Opportunity Act (WIOA) Title I Youth program with funds from the 21st 

Century Community Learning Centers (21st Century CLC) program to deliver a comprehensive 

program for at-risk youth that will utilize a tiered case management service approach. The Best 

Opportunities to Shine and Succeed (BOSS) program will serve 420 at-risk youth enrolled at six 

Broward County high schools who are credit deficient, failed an End of Course (EOC) exam, or 

have documented behavioral problems. Case managers will work with participants to create and 

carry out individualized service strategies that identify the academic supports and services they 

need to complete high school. Each site will offer daily homework help and tutoring to prepare 

student participants for EOC exams that will be supervised by a certified teacher. Credit 

recovery will be offered online two days a week, allowing students to earn high school credit for 

classes they failed during the regular school day. Career and technical education will be offered 

bi-weekly. BOSS also will support career exploration and employability skills development and 

provide entrepreneurial education and work experience opportunities. BOSS will offer the Teen 

Outreach Program®, YMCA Youth In Government Program® and goLEAD youth development 

and service-learning program bi-weekly at each site. The project also will braid funding 

provided under the Library Services and Technology Act to deliver support for researching and 

pursuing postsecondary educational opportunities. 

 

2 The Consulting Agency is the Federal agency that leads monitoring of the individual pilot on behalf of the Federal 

agencies.

3 A Participating Agency is the Federal agency that provides support to the Consulting Agency, as appropriate. For 

each pilot, any agency whose program or funds are involved in the particular pilot is a Participating Agency for that 

pilot.
16

The chart below identifies the waivers the pilot was granted.

Program Waiver Citation

WIOA Title I 

Youth 

Negotiate minimum out-of-school youth 

expenditure amount. For Program Year (PY) 2015 

funds, the applicant is required to meet the 

expectations set forth in DOL’s Training and 

Employment Guidance Letter (TEGL) 23-14. 

Those requirements include spending no less than 

50 percent of the local area’s total youth 

expenditures on out-of-school youth (OSY) using 

PY 2015 funds not counting the expenditures for 

this pilot project. Local areas have two years to 

spend their local youth funds therefore the 50% 

OSY expenditure rate for PY 2015 funds must be 

met by June 30, 2017. 

For PY 2016 funds, the applicant is required to 

spend no less than 60% of the local area’s total 

youth expenditures on OSY not counting the 

expenditures for this pilot project. Local areas have 

two years to spend their local youth funds therefore 

the 60 percent OSY expenditure rate for PY 2016 

funds must be met by June 30, 2018. For the 

following years, DOL will negotiate the local area’s 

expenditure requirement based on a baseline from 

the local area’s expenditures with PY 2014 and PY 

2015 funds, taking into account expenditures used 

for this pilot.

WIOA Sec. 

129(a)(4)(A)

WIOA Title I 

Youth 

Waive WIOA’s eligibility requirements. Approved 

only for the youth participating in the pilot. This is 

not intended to broaden eligibility for WIOA. The 

intent is to address a reporting and documentation 

burden. To lessen the administrative burden, the 

applicant will establish eligibility based on a 

school-wide income designation and student risk 

factors. The applicant asserts all or substantially all 

of the youth in this program would be eligible for 

WIOA under section 129. The applicant asserts 

that analysis of income designation and risk factors 

would result in a substantial overlap with the youth 

eligible for services under section 129 of WIOA. 

WIOA Sec. 129 

(a)(1)(c)
17

Program Waiver Citation

WIOA Title I 

Youth 

Waive Workforce Investment Act (WIA)/WIOA 

performance measures and use proposed alternative 

measures instead. Conditional. The State must 

submit a letter acknowledging the applicant’s 

request for performance flexibility. 

WIOA Sec. 

116(B)(2)(A)(ii)(I 

– III)

21st Century CLC Allow 21st Century CLC funds to be used to 

support authorized activities during the school day. 

Conditional on the written assurance that the funds 

will be used to supplement, and not supplant, other 

Federal, State, and local public funds expended to 

provide programs and activities authorized under 

the 21st Century CLC program and other similar 

programs. 

Secs. 

4201(b)(1)(A) and 

4204(a) of the 

Elementary and 

Secondary 

Education Act 

(ESEA)

Department of 

Education General 

Administrative 

Regulations 

(EDGAR) 

Waive the prohibition against subgranting U.S. 

Department of Education funds unless authorized 

by statute or by 34 CFR §75.708 (b) in order to 

enable the Pilot Lead to subgrant 21st Century CLC 

funds to Hispanic Unity of Florida and the YMCA 

of Broward County to carry out the activities 

described in the approved application. 

34 CFR §75.708 

(a)

Consulting Agency: U.S. Department of Education 

Participating Agencies: U.S. Department of Labor, Institute of Museum and Library Services

Pilot Lead: Chicago Department of Family and Support Services (IL) 

The Chicago Department of Family and Support Services will braid Head Start funds and 

Workforce Innovation and Opportunity Act Title I Youth funds from the Chicago-Cook 

Workforce Partnership to provide comprehensive services for young mothers and their children 

through a two generational model that addresses the education, employment, and developmental 

needs of parents and their children. The Chicago Young Parents Program (CYPP) will serve 210 

young mothers between the ages of 14 and 24 who have children under age 6 and who have 

dropped out of high school, postsecondary education, and/or the workforce or who are at risk of 

dropping out. Children will be enrolled in Head Start or Early Head Start depending on their 

age, and will remain eligible for the program through the duration of the parent’s participation in 

CYPP. Each CYPP participant will be assigned a mentor who will lead weekly enrichment 

sessions for participants that will include social-emotional learning and cognitive behavioral 

therapy, conduct biweekly home visits using the Parents as Teachers curriculum, and provide 

other individualized support to participants throughout their participation in the program. CYPP 

also will provide participants with a paid, part-time work experience at a Head Start center and 

job training to prepare them to join the early learning workforce. Additionally, participants and 

their children will be brought together once a month for age-appropriate developmental 

activities.
18

The chart below identifies the waivers the pilot was granted. 

Program Waiver Citation

Head Start Waive the requirement for the redetermination of 

income eligibility for all children transitioning from 

Early Head Start to Head Start to allow all participants 

to remain eligible for the CYPP for the two years of the 

program. The waiver request is granted for the children 

participating in this Pilot.

Head Start 

Regulation 45 

CFR 1305.4 

(i)(4)

Head Start Waive income eligibility requirements. Household 

income is the income assessed to determine child 

eligibility. Waiver allows youth living with 

parents/relatives or guardians, regardless of 

parent/relative/guardian income, to be determined 

eligible for enrollment in CYPP and their children to be 

determined to be eligible for Head Start or Early Head 

Start. This request is approved for the children 

participating in this pilot. 

Head Start 

Regulation 45 

CFR 1305.4(c) 

Workforce 

Innovation and 

Opportunity Act 

(WIOA) Title I 

Youth 

Waive WIA/WIOA performance measures and use 

proposed alternative measures instead for the youth 

participating in this Pilot. This request is conditionally 

approved. The State must submit a letter acknowledging 

the applicant’s request for performance flexibility. 

WIOA Sec. 

116. 

(b)(2)(A)(ii)(IIII)

WIOA Title I 

Youth 

Waive WIOA eligibility requirements and permit inschool youth (ISY) to be counted as OSY only for youth 

participating in this project, and for fiscal accounting 

purposes only. This request is approved only for the 

youth participating in the pilot. The Chicago Cook 

Workforce Partnership anticipates that without the 

waiver it would meet the requirements of WIOA Sec. 

129(a)(1). The waiver addresses the fiscal accounting 

reporting and documentation burden of separately 

keeping track of ISY and OSY.

WIOA Sec. 

129(a)(1)

Department of 

Education 

General 

Administrative 

Regulations 

(EDGAR) 

Waive the prohibition against subgranting U.S. 

Department of Education funds unless authorized by 

statute or by 34 CFR §75.708 (b) in order to enable the 

Pilot Lead to subgrant P3 start-up grant funds to Chapin 

Hall and SGA Youth and Family Services to carry out 

the activities described in the approved application. 

34 CFR 

§75.708 (a) 

Consulting Agency: U.S. Department of Health and Human Services

Participating Agency: U.S. Department of Labor 
19

Pilot Lead: City of Indianapolis (IN) 

The City of Indianapolis will provide comprehensive, concentrated, and coordinated services to 

low-income, disconnected youth ages 14 through 24 who reside within two public housing 

communities that are located in the city’s Opportunity Zone, a collective impact initiative 

modeled on the Northside Achievement Zone in Minneapolis, MN. Indiana Black Expo, a 

project partner, will provide two “connectors” who will each assist approximately 40 youth at a 

time develop individual service/success plans and access services from 40-50 public and private 

nonprofit partners such as EmployIndy, the local workforce development board, and HealthNet, 

a health care provider. EmployIndy will blend funds from YouthBuild and the youth program 

authorized by Title I of WIOA to provide employment and training services to participants. The 

project will braid funds from the adult program authorized by Title I of WIOA. 

The pilot was granted the flexibility to blend funds from YouthBuild and the WIOA Title I 

Youth program. 

Consulting Agency: U.S. Department of Labor 

Pilot Lead: Eastern Kentucky Concentrated Employment Programs (KY)

The Eastern Kentucky Concentrated Employment Program (EKCEP), Inc., a local workforce 

development board, will work with Partners for Education at Berea College and the Kentucky 

Highlands Promise Zone to provide services and activities to address the needs of 1,000 

disconnected youth in the rural Southeastern Kentucky Promise Zone. The project will primarily 

serve: (1) at-risk youth ages 16 through 18 who are enrolled in school, with a particular focus 

those youth who are returning to school because the state’s compulsory school age increases this 

year to age 18 and those in-school youth that are disengaged; (2) young parents with career or 

educational needs; and (3) youth ages 19 through 24 who are neither enrolled in school nor 

working. The project will implement career focused programs in the high schools, an early 

warning system to identify youth who are at-risk of dropping out, a Families and Schools 

Together program for youth parents, individual career coaching and advising, and work-based 

career learning opportunities (including internships and on-the-job training). EKCEP will blend 

funds from Workforce Innovation and Opportunity Act Title I Youth, GEAR UP, and Promise 

Neighborhoods and braid funds from Full Service Community Schools. 

The chart below identifies the waivers the pilot was granted. 

Program Waiver Citation

GEAR-UP Waive the GEAR-UP requirement that grant funds be used 

to serve a certain grade-level/cohort: 

(a) Each cohort to be served by a Partnership or State must 

be from a participating school—(1) That has a 7th grade; 

and (2) In which at least 50 percent of the students are 

eligible for free or reduced-price lunch. 

34 CFR 

694.3(a); HEA 

sec. 404B(d) 
20

Program Waiver Citation

GEAR-UP Waive the GEAR-UP requirement that grant funds be used 

to serve schools that meet certain requirements:

(a) In general. Each cohort to be served by a Partnership 

or State must be from a participating school—(1) That has 

a 7th grade; and (2) In which at least 50 percent of the 

students are eligible for free or reduced-price lunch under 

the National School Lunch Act. 

34 CFR 

694.3(a); HEA 

sec. 404B(d) 

GEAR-UP Waive GEAR UP requirement that:

The Secretary may award a grant under this division to an 

eligible entity described in paragraphs (1) and (2) of 

subsection (c) for— 

(A) six years; or

(B) in the case of an eligible entity that applies for a grant 

under this division for seven years to enable the eligible 

entity to provide services to a student through the student’s 

first year of attendance at an institution of higher 

education, seven years. 

HEA Sec. 

404A(b)(2) 

GEAR-UP Waive the GEAR-UP matching requirement for the portion 

of GEAR-UP grant funds that are blended in the Pilot. 

HEA Sec. 

404C(b) 

WIOA Title I 

Youth 

Negotiate Minimum OSY Expenditure requirement. For 

the 1st year of the pilot, the applicant would be required to 

meet the expectations set forth in TEGL 23-14. For the 

following years, DOL will negotiate the local area’s 

expenditure requirement based on a baseline from the local 

area’s expenditures in 2014, taking into account 

expenditures used for this pilot, and requiring no less than 

50% of the local area’s total youth allocation be spent on 

OSY. The local grantee will need to demonstrate notable 

progress toward the WIOA requirement of spending 75% 

of the youth funds for OSY. 

WIOA Sec. 

129(a) (4) (A)

WIOA Title I 

Youth 

Waive WIOA eligibility requirement that OSY and ISY

have “specific barriers” to be served. Approved only for 

the youth participating in the pilot.

WIOA Sec. 

129(a) (1) (B) 

and (C) 

WIOA Title I 

Youth 

Waive WIA/WIOA performance measures and use 

proposed alternative measures instead. Approved with the 

condition that the State must submit a letter acknowledging 

the applicant’s request for performance flexibility. 

WIOA Sec. 116. 

(b)(2)(A)(ii)(IIII)

Consulting Agency: U.S. Department of Education 

Participating Agency: U.S. Department of Labor
21

Pilot Lead: City of Baton Rouge/Parish of East Baton Rouge (LA) 

Baton Rouge will establish a coordinated infrastructure that will target 84 disconnected youth 

ages 14 through 24 who attend specialized schools serving youth who are two or more years 

behind for their grade in the local public school system. Using a random control treatment study 

design, the pilot will serve a randomly stratified sample of youth and has two objectives: (1) to 

facilitate and strengthen cross-sector partnerships among provider agencies, industry/employers, 

elementary and secondary schools, post-secondary institutions, juvenile justice providers, and 

local government; and (2) to create intensive and individualized pathways to success in 

education and careers for disconnected youth. All students enrolled in the targets schools will 

participate in alternative education focused on accelerated learning with individualized 

instruction, as well as career and technical education, flexible scheduling, service learning, and 

low student-teacher ratios. Those randomly selected into the treatment group will receive 

additional individualized and tailored services and supports. The pilot treatment group will be 

guided into a career pathway by a school-based career coach. The performance partnership pilot 

will be steered by the Baton Rouge Partnership Advisory Council that will provide specialized 

knowledge and community advocacy in order to empower a partnership to reconnect youth for 

positive life outcomes.

The chart below identifies the waivers the pilot was granted. 

Program Waiver Citation

Carl D. Perkins 

Career and 

Technical 

Education Act of 

2006 

Waive grade eligibility requirement and allow 

provision of services starting in the 6th grade. 

Section 315 of the Carl 

D. Perkins Career and 

Technical Education 

Act of 2006 (Public 

Law 109-270 ) 

WIOA Title I 

Youth Program 

Waive WIA/WIOA performance measures and 

allow the use of proposed measures instead, with 

the condition that the State must submit a letter 

acknowledging the applicant’s request for 

performance flexibility by January 31, 2015. 

WIOA Sec. 116. 

(b)(2)(A)(ii)(I- III)

Consulting Agency: U.S. Department of Education

Participating Agency: U.S. Department of Labor

Pilot Lead: Oklahoma Department of Human Services (OK)

The Oklahoma Department of Human Services will implement a project to help youth in foster 

care complete educational requirements for high school graduation, postsecondary education, 

and employment. Career academies, Communities in Schools, and Check & Connect are the 

evidence-based and promising practices in education that will be used in the project. The project 

will target youth in local public schools who are ages 14 to 18 and provide transition services 

after graduation for postsecondary education and employment services. An estimated 150 youth 
22

will be served by the project. The Department will braid funds from Workforce Innovation and 

Opportunity Act Title I Youth and Adult programs, Now Is the Time Healthy Transitions, Carl 

D. Perkins Career and Technical Education Act, AmeriCorps, and Chafee Education and 

Training Vouchers. 

The chart below identifies the waivers the pilot was granted.

Program Waiver Citation

WIOA Title I 

Youth 

Negotiate minimum OSY expenditure amount. For 

Program Year (PY) 2015 funds, the applicant is required 

to meet the expectations set forth in DOL’s TEGL 23-

14. Those requirements include spending no less than 

50 percent of the local area’s total youth expenditures 

on OSY using PY 2015 funds not counting the 

expenditures for this pilot project. Local areas have two 

years to spend their local youth funds therefore the 50% 

OSY expenditure rate for PY 2015 funds must be met 

by June 30, 2017. 

For the following years, the U.S. Department of Labor 

will negotiate the local area’s expenditure requirement 

based on a baseline from the local area’s expenditures in 

2014, taking into account expenditures used for this 

pilot, and requiring no less than 50% of the local area’s 

total youth allocation be spent on OSY. The local area 

plans to use around 10% of their local area funds for this 

project and all funds will be used for ISY (about 50 

youth per year). The local grantee will need to 

demonstrate notable progress toward the WIOA 

requirement of spending 75% of the youth funds for 

OSY. 

WIOA Sec. 

129(a)(4)(A)

WIOA Title I 

Youth 

Waive Workforce Investment Act (WIA)/WIOA 

performance measures and use proposed alternative 

measures instead. Conditional. The State must submit a 

letter acknowledging the applicant’s request for 

performance flexibility. 

WIOA Sec. 

116(B)(2)(A)(ii)

(I – III)

Consulting Agency: U.S. Department of Labor 

Pilot Lead: Ysleta del Sur Pueblo (TX)

Ysleta del Sur Pueblo, a Federally recognized Indian tribe, will use P3 authority to establish the 

Tigua Institute of Academic and Career Development Excellence to provide counseling and 

educational services to 85 youth between the ages of 14 and 24. A Wraparound Counselor will 

work with each youth to develop an Individualized Service Plan (ISP) of education and training 
23

services and supports, as well as coordinate the implementation of the plan. Youth also will 

participate in the Tigua Leadership Curriculum that will build the youths’ skills and help them 

successfully navigate through various systems to improve their chances of completing high 

school and pursing career and technical training, postsecondary education, or employment. To 

carry out the pilot, Ysleta del Sur Pueblo will blend AmeriCorps funding from the Corporation 

for National and Community Service with funding from a Library Enhancement grant awarded 

by the Institute for Museum and Library Services. 

The chart below identifies the waiver the pilot was granted. 

Program Waiver Citation

AmeriCorps Waive matching requirements. 42 U.S.C. § 12571; Pub. L. 

113-76, Title IV, § 402; 45 

C.F.R. §§ 2521.35, .45, .60, 

.70 

Consulting Agency: Corporation for National and Community Service

Participating Agency: Institute of Museum and Library Services 

Pilot Lead: Workforce Development Council of Seattle - King County (WA) 

The Workforce Development Council of Seattle - King County (Council) will implement an 

innovative re-engagement strategy to achieve better educational and employment outcomes for 

200 disconnected youth ages 16 to 24 who are neither enrolled in school nor employed. The 

pilot will include three key components: (1) strategic coordination of workforce development 

services with the state’s unique Open Doors policy, which provides K-12 funding for 

reengagement programs; (2) utilizing AmeriCorps members to develop a regional outreach 

strategy aimed at placing the hardest to serve youth in the region in programs that best reflect 

their interests and needs; and (3) advancing efforts toward a shared data system and common 

intake process that will enhance the coordination and targeting of services across the county. 

The Council will braid State basic education funding with Workforce Innovation and 

Opportunity Act Title I Youth program funds and funding from a Reentry Employment 

Opportunities grant.

The chart below identifies the waiver the pilot was granted. 

Program Waiver Citation

Reentry Employment 

Opportunities (REO) 

Consider foster care and homeless 

youth to be eligible participants under 

the 10% exemption in REO. 

Approved only for the youth 

participating in the pilot.

Second Chance Act Sec. 

212(a)(2)

Consulting Agency: U.S. Department of Labor 
24

FY 2015 (Round 2) Pilot Finalist 

Summary of Proposed Project

Pilot Lead: Maricopa County Education Service Agency (AZ)

Maricopa County Education Service Agency (MCESA), Maricopa County Workforce 

Department, Maricopa County Regional School District, and the Arizona Manufacturing 

Apprenticeship seek to create an “earn and learn” apprenticeship program for up to 610 out-ofschool youth ages 16 to 24 that will prepare them for skilled jobs in the local manufacturing 

industry. To support the program, MCESA would blend funds from the Workforce Innovation 

and Opportunity Act Title I youth program, Title I, Part A of the Elementary and Secondary 

Education Act (ESEA), and the P3 start-up grant. An independent evaluator would carry out a 

randomized controlled trial to evaluate the impact of the program on the outcomes of 

participating youth. 

The chart below identifies the waivers the Agencies are considering granting under P3 or other 

waiver authority. 

Program Waiver Citation

WIOA Title I Youth Waive requirements of WIOA 

performance measures for youth 

participating in the pilot and instead 

use the project’s proposed outcome 

measures

WIOA Section. 

116(b)(2)(A)(ii)

Title I, Part A of the 

Elementary and 

Secondary Education 

Act

Waive the limitation on serving 

individuals older than age 21 

ESEA Section 

1115(c)(1)(A)(i)

Title I, Part A of the 

Elementary and 

Secondary Education 

Act

Waive the Tydings Amendment to 

extend to September 30, 2018, the 

period of availability of $60,000 of 

fiscal year 2015 Title I, Part A funds 

being used to support the Pilot . 

General Education Provisions 

Act (GEPA) Section 421(b) 

Consulting Agency: U.S. Department of Education 

Participating Agency: U.S. Department of Labor 
25

FY 2016 (Round 3) Pilot Finalists 

Summaries of Proposed Projects

Pilot Lead: New York State Department of Education

Working with school district partners in Albany and Rochester, the New York State Education 

Department (NYSED) will test the effectiveness of integrated case management in identifying 

and serving up to 120 disconnected youth who face significant barriers on their path to the 

future, with a particular focus on youth who have dropped out of school or who have been 

released from the juvenile justice system within the previous six months. A transition 

coordinator at each site will receive referrals of disconnected youth from school districts, child 

welfare agencies, and the juvenile justice system. The transition coordinator will provide 

intensive case management for youth based on jointly developed individual service plans. Youth 

will be linked with existing educational and employment services, and the transition coordinator 

will continue to follow up and track progress for up to four months. The project also will carry 

out a randomized controlled trial that will examine the impact of pilot services on youth 

educational and employment outcomes. Pilot funding includes 21st Century Community 

Learning Centers funds awarded to NYSED and Juvenile Justice and Delinquency Prevention 

Act Title II funds available from the New York State Division of Criminal Justice Services.

The chart below identifies the waivers the Agencies are considering granting under P3 or other 

waiver authority. 

Program Possible Waiver Citation

21st Century 

Community 

Learning Centers

Waive the requirement in 34 CFR 76.50(b) that the 

authorizing statute determines the extent to which a 

State may use grant funds directly and make subgrants 

to eligible applicants, in order to permit the grantee to 

subgrant $150,000 of the State’s FY 2016 21st CCLC 

program funds reserved for “State activities” under 

section 4202(c)(3) of the ESEA to two local educational 

agencies to carry out various authorized activities, as 

described in the grantee’s P3 application. 

34 CFR 76.50(b) 

21st Century 

Community 

Learning Centers

Waive the requirement in section 4201(b)(1)(A) of the 

ESEA that community learning centers assist “students” 

so that the two local educational agencies to which 

subgrants will be awarded may use 21st Century 

Community Learning Centers funds to support transition 

coordinators who work with youth who are not enrolled 

in school to help them resume their educations by reenrolling in elementary or secondary school, or 

participating in State-approved high school equivalency 

and Learn-to-Work programs, as described in the 

grantee’s P3 application. 

Section 

4201(b)(1)(A) of 

the ESEA
26

Program Possible Waiver Citation

21st Century 

Community 

Learning Centers

Waive the requirement in section 4201(b)(1)(A) of the 

ESEA that 21st CCLC program activities be carried out 

during non-school hours or periods when school is not 

in session to enable transition coordinators to provide 

services during the school day to youth who have reenrolled in elementary or secondary school. 

Section 

4203(b)(1)(A) of 

the ESEA

Consulting Agency: U.S. Department of Education 

Participating Agency: U.S. Department of Justice 

Pilot Lead: Sacramento (CA) Housing and Redevelopment Agency

The Sacramento Housing and Redevelopment Agency proposes to launch a pilot that will take a 

multi-disciplinary approach to serving 100 disconnected youth ages 16 to 24 who reside in a 

Promise Zone and who are homeless or at risk of becoming homeless, aging out of foster care, or 

on probation. The pilot will implement a housing first strategy that addresses the housing needs 

of participants before they are referred for other services. Once youth are stabilized in a safe 

environment, the program partners will work with the youth to attain education and employment 

goals. Collaboration among the partners will be enhanced by the development of an integrated 

data management system. Additionally, all front-line staff will be trained to deliver “youth 

mental health first aid” to help an adolescent who is experiencing a mental health or addictions 

challenge or is in crisis. The pilot will utilize funds from the Street Outreach Program, 

YouthBuild, and the WIOA Title I Youth program. 

The chart below identifies the waivers the Agencies are considering granting under P3 or other 

waiver authority. 

Program Possible Waiver Citation

WIOA Title I 

Youth 

Waiver to allow youth (who participate in this pilot) 

who attend a high school equivalency program funded 

by public K-12 to be considered “out of school” for the 

purposes of WIOA eligibility. 

20 CFR § 681.230 

WIOA Title I 

Youth 

Waiver to exclude only those WIOA Title I Youth 

funds allocated to P3 from the calculation of the local 

area’s 75% minimum out-of-school youth expenditure 

requirement. 

WIOA Sec. 

129(a) (4) (A)

Consulting Agency: U.S. Department of Health and Human Services 

Participating Agency: U.S. Department of Labor 
27

Pilot Lead: Los Angeles (CA) County Community and Senior Services 

Los Angeles County Community and Senior Services proposes a pilot that will coordinate, 

expand, and evaluate career mentoring programs that will serve up to 225 disconnected youth 

ages 18 through 24 from the foster care system, the probation system, and Temporary Assistance 

for Needy Families. The pilot will provide youth with short-term exposure to public service 

careers through on-the-job training and guidance and support provided by public service 

employees who have been trained as career mentors. The pilot will include funds from the 

Workforce Innovation and Opportunity Act Title I youth program and Social Innovation Fund. 

An independent evaluator will collect data on participant experiences and outcomes and develop 

a “blueprint guide” to replicating the program. 

The chart below identifies the waivers the Agencies are considering granting under P3 or other 

waiver authority. 

Program Possible Waiver Citation

WIOA Title I Youth Waive WIOA performance measures and use 

proposed measures instead. 

WIOA Sec. 

116(b)(2)(A)(ii)(I-III)

Consulting Agency: U.S. Department of Labor 

Participating Agency: Corporation for National and Community Service 

Pilot Lead: City of Hartford (CT) 

The City of Hartford, in partnership with the State of Connecticut, Capital Workforce Partners, 

Connecticut Center for Advanced Technology, and two employer partnerships—Metro Hartford 

Alliance for Careers in Health Care and Advanced Manufacturing Employer Partnership—will 

engage 100 disconnected, justice-involved youth ages 14 through 24 who reside in the North 

Hartford Promise Zone in career pathways that offer career exploration, the opportunity to 

develop career competencies, and paid work-based learning. Throughout the pilot, each youth 

will be assigned a case manager who will help them navigate the educational, employment, 

health, service, mentorship, and supportive systems they need to succeed. Additional support 

will be provided by peer mentors who will be recruited from among youth leaders who have 

successfully completed one of the city’s Workforce Innovation and Opportunity Act (WIOA) 

Title I Youth programs. The pilot also will better integrate data systems used by the city’s 

youth-serving programs to aid case managers in identifying service gaps, matching youth to 

needed services and programs, and tracking their progress. The pilot will braid funds from the 

WIOA Title I Youth program, a Career Pathways for Youth grant, a Social Innovation Fund 

subgrant, and a Teenage Pregnancy Prevention Program grant. 

The chart below identifies the waivers the Agencies are considering granting under P3 or other 

waiver authority. 
28

Program Possible Waiver Citation

WIOA Title I 

Youth 

Waiver of enrollment cap that precludes a local area 

from determining that more than 5% of in-school youth 

newly enrolled in a program year are eligible based on 

the “requires additional assistance to complete an 

educational program or to secure or hold employment” 

criterion.

20 CFR 681.310(b) 

WIOA Title I 

Youth 

Waiver of the definition of “low-income” individual 

applicable to youth served by the P3 program. 

20 CFR 681.250(d) 

WIOA Title I 

Youth 

Waiver to allow youth who dropped out of school to 

keep their designation as an out-of-school youth (OSY) 

after entering a re-engagement program, recovery 

program, overage/under-credited program, or adult 

education, when such youth would not already keep 

their designation as OSY per the regulations. 

20 CFR 681.230 

WIOA Title I 

Youth 

Waiver to allow applicant to serve youth who are 

identified as at-risk of becoming justice involved by the 

criminal justice system, or by a juvenile diversion 

program; youth who are at risk of becoming justice 

involve could include, but are not limited to, youth who 

are victims of crimes or youth who are members of 

gangs.

20 CFR 

681.210(c)(4) and 20 

CFR 681.220(d)(3) 

WIOA Title I 

Youth 

Waiver of out-of-school priority to permit less than 75 

percent of funds available to the local area to be used to 

provide youth workforce investment services for outof-school youth. 

WIOA sec. 129(a)(4) 

Teen 

Pregnancy 

Prevention 

Program

Waiver to use alternate performance measures. HHS Announcement 

Number AH-TP-1-

15-002. Funding 

Opportunity 

Announcement. 

Consulting Agency: U.S. Department of Labor 

Participating Agency: U.S. Department of Health and Human Services 

Pilot Lead: New York City (NYC) Department of Youth and Community Development 

The New York City Department of Youth and Community Development (DYCD), the New 

York City Administration for Children’s Services (ACS), and nonprofit partner Opportunities for 

a Better Tomorrow will provide services for 50 vulnerable young parents aged 17 to 24 and their 

children through a two-generational model that addresses the education, employment and 

developmental needs of parents and their children. The pilot will improve participants’ access to 
29

multiple career pathways through activities that will include guaranteed childcare through ACS, 

high school equivalency preparation, work readiness and occupational skills training, paid work 

experiences, supportive services, and parenting support. The pilot also will provide personalized 

enrichment and support plans for participants through a Child Care Navigator. DYCD and its 

partners will support the pilot by braiding funds from the Workforce Innovation and Opportunity 

Act (WIOA) Title I Youth program, the Community Service Block Grant, and the Child Care 

and Development Block Grant. A quasi-experimental evaluation will examine whether: 

(1) providing child care and supportive parenting services for young parents increases their 

enrollment and attendance in education and employment training; (2) providing parenting 

workshops and supports to young parents increases their parenting skills; and (3) facilitated 

enrollment in child care increases children’s enrollment and attendance in quality child care 

programs. 

The chart below identifies the waivers the Agencies are considering granting under P3 or other 

waiver authority. 

Program Possible Waiver Citation

WIOA Title I Youth 

program 

Waive WIOA performance measures relating to 

median earnings, credential attainment, and skill 

gains and use proposed alternative measures 

instead.

WIOA Sec. 116 

(b)(2)(A)(ii)(I- III)

Consulting Agency: U.S. Department of Health and Human Services 

Participating Agency: U.S. Department of Labor 

Pilot Lead: Sandoval County – Juvenile Services

In partnership with Bernalillo Public Schools, the Santo Domingo Pueblo, and others, Sandoval 

County – Juvenile Services will establish within the Santo Domingo Pueblo a Reception 

Assessment Center (RAC) and Learning Lab, a detention diversion program designed to provide 

law enforcement an alternative to incarceration for youth. The RAC and Learning Lab will 

provide tutoring and credit recovery, preparation for a high school equivalency credential, life 

skills instruction, as well as case management services. Up to 482 disconnected youth from the 

Santo Domingo, San Felipe and Cochiti Pueblos and surrounding communities are expected to 

be served. The pilot will use funds from the Indian and Native American Program authorized by 

Section 166 of Workforce Innovation and Opportunity Act and the Santo Domingo Pueblo will 

provide child care through Head Start for participants who are parents. 

The chart below identifies the waivers the Agencies are considering granting under P3 or other 

waiver authority. 
30

Program Possible Waiver Citation

WIOA, 

Comprehensive 

Services 

Program, Section 

166 

Waive the requirement of a low-income individual as 

defined in section 3 (36) of WIOA for the Comprehensive 

Services Program. 

20 CFR § 

684.300(b)(3) 

WIOA, 

Comprehensive 

Services 

Program, Section 

166 

Waive §684.430 of the Youth allotment. (3) A low-income 

individual as defined at WIOA sec. 3(36) except up to 5% 

of the participants during a program year in an INA youth 

program may not be low-income individuals provided they 

meet the eligibility requirements of paragraphs (a)(1) and 

(2) of this section. 

20 CFR § 

684.430(a)(3) 

Consulting Agency: U.S. Department of Labor 

Participating Agency: U.S. Department of Health and Human Services