PREPARED BY:

Larry Pasti, The Forum for Youth Investment 

Tara Smith, JFF
IDENTIFYING AND ADDRESSING BARRIERS TO 

PROGRAM IMPLEMENTATION 

A TOOL FOR COMMUNITY REFLECTION

BACKGROUND

Helping to reconnect youth back to education and employment and get them on a path 

to a successful transition to adulthood that includes economic self-sufficiency, skills that 

support independent living, and improved health, mental health and well-being can be 

challenging. Youth development stakeholders and beneficiaries (i.e., the youth 

themselves) describe significant challenges that hinder meaningful improvements in 

education, employment, health, and well-being outcomes. Such challenges include: poor 

coordination across the systems that serve youth; policies that make it hard to engage 

the most vulnerable youth with services and resources to help them overcome personal 

barriers; fragmented data systems that inhibit the flow of information across systems to 

improve results; and administrative requirements that impede holistic approaches to 

serving youth; among other factors. Addressing these challenges requires services and 

expertise from multiple systems, including education, health and mental health, 

workforce development, job training, housing, social services, criminal justice, child 

welfare, and other systems.

Effective coordination between these systems requires an understanding of how funds 

and programs can be leveraged. Resources are available to serve disconnected or 

opportunity youth from all levels of government, from corporations, and from private 

philanthropy. These resources often start at the federal level, where allocations, rules, 

and regulations regarding their use are made. It is important to note, however, that 

federal programs often give states and communities (through workforce and school 

boards) the power, within limits, to make additional discretionary decisions regarding 

the use of these funds. The differing levels of authority can sometimes make it difficult to 

determine at what level certain policy decisions are made and where community 

practitioners and youth have the power to intervene in these decision-making processes.

Because of these complexities, community leaders often find it challenging to align and 

integrate resources in order to achieve shared goals. All levels of government have 

engaged in various interagency efforts that work to address barriers or unintended 

policy consequences that appear to limit innovation, such as eligibility requirements, 

performance reporting, service strategies or how funds can be used. Sometimes barriers 

originate at the federal level; other times barriers exist at the state or local level. In some 

cases, local or state entities exercise their own authority to introduce additional 

requirements that federal policymakers did not intend or foresee. Sometimes, however, 

the barrier is one of perception, i.e., “We’re not sure why, but it’s just always been done 

this way.” In other instances, organizations misinterpret policies or the origin of policy 

decisions.

This technical assistance tool was funded by the U.S. Department of Education under contract ED-ESE-15-A-0011-0002. The content does 

not necessarily reflect the views or policies of the U.S. Department of Education and is not an endorsement of any products or organizations.

The authors wish to thank staff at the U.S. Departments of Education, Labor, and Health & Human Services for their review of earlier drafts. 

They also appreciate the contributions of staff from P3 Rounds 1 and 2 projects, especially Kristin Ferguson-Colvin, Sue Gallagher, and 

Elizabeth Stover.
2

PURPOSE AND HOW TO USE 

THIS TOOL

This tool will help communities identify, align, and 

integrate resources so they can strengthen systems and 

partnerships to design high-impact programming for 

opportunity youth. It is designed to lead communities 

through a series of questions that should allow them to 

better determine when an innovative solution is needed to 

implement strategies that serve their goals. It is likely that 

the tool will not be completed in one session and 

communities may need to bring in additional support or 

partners to work through some steps. 

Plan to spend 

more than 

one session 

working 

through this 

tool with key 

stakeholders.

In the first step, stakeholders must identify the population that they intend to serve, 

specifying the challenges those youth face and the goal(s) that improved system

alignment will help them achieve. Next, this tool assesses 

both current and potential resources available to that 

population, including local partnerships and services, in 

an effort to identify what is working well and what needs 

to change. In the third step, stakeholders identify the key 

strategies and accompanying tactics for achieving the 

goal(s) outlined in step 1. Finally, this tool will assist 

communities with the development of specific strategies 

and tactics to address specific barriers in order to achieve 

concrete solutions. The path below illustrates how to work 

through the questions as they apply.

Strategies are 

the overall plans 

for achieving the

goal, while 

tactics are the 

individual steps 

involved in each 

strategy.

Community Reflection Process for Program Innovation

Step 1

Goal Setting

•Target

population

•Overall 

goal(s)

Step 2

Partnership & 

Resource 

Assessment

• Duplications

•Gaps

•Opportunities

Step 3 

Strategy 

Identification

•Key tactics

Step 4

Strategy 

Analysis

• Current 

status

• Current 

funding

•Potential 

funding 

opportunities

Step 5

Barrier 

Identification

• Restrictions

• Limitations

Step 6

Barriers 

Analysis

•Type

•Source

Step 7 

Identifying 

Solutions
3

STEP 1: GOAL SETTING

In this step, stakeholders should specifically identify the target population for their 

initiative or program, including characteristics such as age, income, and risk and 

resilience factors. Then, stakeholders should clearly state their goal for improving 

outcomes and strengthening assets for that target population.

Goals that are 

specific, 

measurable, 

attainable, relevant, 

and time-bound 

(SMART goals) 

help to ensure that 

stakeholders are 

“on the same page” 

about the planned 

work.

Target Population

Our desired population is: [pick all that apply]

AGE

□

□

□

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

□ 

14–15

16–18

19–24

INCOME

 

 

percent at or below poverty level

percent above poverty level

No income eligibility

Other 

YOUTH RISK FACTORS

Child welfare (foster care) involvement

Disabilities: mental/behavioral health & physical health

Housing needs: homeless or runaway youth

Juvenile/criminal justice involvement

Left high school before completion

Parenting

Unemployed or underemployed

Zip Code

Other 

YOUTH RESILIENCE FACTORS

Community supports

Coping skills

Family supports

Future orientation

Goal setting

Mentor(s)

Prosocial peer network

Other 
4

Overall Goal

STEP 2: PARTNERSHIP & RESOURCE 

ASSESSMENT

In this step, stakeholders should assess the partner organizations and funders who are 

already engaged in the initiative or program as well as those who need to be engaged to 

successfully meet the identified goals.

In the table below, stakeholders should identify the partners and funders who are 

currently collaborating in or contributing to work towards the identified goal. Where 

possible, identify the key contact or lead in each organization. Detailing the roles and 

responsibilities that each partner is responsible for, and the resources (human, material, 

financial, administrative, technical, political, other) that are being contributed, is 

important for identifying gaps and duplications across the partnership network.

Partner / Funder Category Organizations & 

Key Contacts 

Roles / Responsibilities /

Resources

□ Community members, 

mentors, parents, youth 

engagement

□ Community service 

organizations
5

Partner / Funder Category Organizations & 

Key Contacts 

Roles / Responsibilities /

Resources

□ Corporate or philanthropic 

foundation

□ Early childhood education 

(e.g., Head Start, Pre-K, 

preschool) and childcare

□ Education, traditional K–

12 and charter schools

□ Education, non-traditional 

(e.g., career/technical 

education, 

apprenticeships, drop-out 

recovery programs, 

alternative high schools, 

etc.)

□ Employers

□ Ethnic community-based 

groups

□ Faith-based organizations 

or youth groups

□ Housing
6

Partner / Funder Category Organizations & Roles / Responsibilities /

Key Contacts Resources

□ Juvenile/criminal justice 

(includes law enforcement 

and courts)

□ Libraries, museums, etc.

□ Mental/behavioral health

□ Postsecondary/ higher 

education

□ Public health

□ Social services/ human 

services

□ Workforce Development 

Boards / American Job 

Centers

□ Youth councils or other 

organized youth groups

□ Other (please specify)
7

After completing the table, stakeholders should assess where there are duplications and 

gaps in partner roles, responsibilities, and resources. Stakeholders could then work 

with partners to identify opportunities for more efficiently, effectively, and equitably 

leveraging contributions.

What duplications in roles, responsibilities, and resources were identified?

Stakeholders should also assess where there are gaps in the partnership. Gaps can be 

more difficult to address than duplications, so stakeholders should carefully detail 

missing partners.

Which partners not currently active in your work would be helpful to the 

collaboration?

What additional resources need to be leveraged for your work to be 

successful?

Based on the identified duplications and gaps, the stakeholders should then determine if 

there are any opportunities, both in the near-term and longer-term, for the partnership 

to better leverage resources and relationships in support of the overall goal.

What are the near-term and longer-term opportunities for more 

efficiently, effectively, and equitably leveraging partner contributions?
8

STEP 3: STRATEGY IDENTIFICATION

In this step, stakeholders identify the specific strategies and tactics they will implement, 

leveraging the partners and resources identified in Step 2, to achieve the goal defined in 

Step 1. Stakeholders may pursue multiple strategies, or tactics within a strategy, to 

increase opportunities for learning and success.

Strategy statements 

should be specific and 

include the tactics, or 

steps, required. Try to 

include as many details 

as possible. For example:

- Who will do it?

- What will they do?

- How will they do it?

- When will it happen?

- How long will it take?

- Why is it important?

- Where will the work 

occur?

Strategy 1:

Strategy 2: Strategy 3:
9

 : 

STEP 4: STRATEGY ANALYSIS

In this step, stakeholders will analyze each of the strategies identified in Step 3. Print 

additional sheets as necessary. Rewrite the strategy being analyzed in the box below.

Strategy #

Current Status of Strategy Implementation

Are you able to effectively implement or accomplish this strategy now without making 

changes, addressing barriers or requesting flexibilities? Stakeholders should be sure to 

document strategy progress and positive outcomes that the partnership network has 

achieved, as well as the work that cannot be implemented or accomplished in current 

conditions.

Be sure to 

share what’s 

working with 

your network 

and recognize 

the key 

contributions 

of partner 

organizations!

□ Yes, we can effectively implement or accomplish the strategy.

Explain:

□ No, we cannot effectively implement or accomplish the strategy.

What work within this strategy are you not able to implement or 

accomplish?
10

Current Funding Sources Supporting Strategy Implementation

What are the primary sources of funding that currently support strategy 

implementation? Include the name of the partner who accesses these funds and other 

details as appropriate.

Federal:

State:

Local City/County:

Corporate/For-profit: 

Philanthropic/Non-profit:

Other:
11

Potential Opportunities for Blending, 

Braiding, and Aligning Funding

Federal funding for programs serving 

opportunity youth is wide-ranging. 

During the first three rounds of the 

Performance Partnership Pilots for 

Disconnected Youth initiative (P3) that 

was first implemented in 2015, federal 

agencies identified more than 40 

programs whose resources may be 

targeted for blending, braiding, or 

aligning to better serve this population. 

Stakeholders working to innovate more 

effective services for opportunity youth 

should familiarize themselves with 

these key terms:

□ Blended funding – Combines funds from two or more funding sources together to 

fund a specific part of a program or initiative. When blended, expenditures are not 

necessarily allocated and tracked by individual fund sources.

□ Braided funding – Coordinates funds from two or more funding sources to 

support the total cost of a program or initiative. When braided, expenditures are 

allocated and tracked by individual fund source.

□ Aligned funding – Two or more organizations organize to more efficiently use 

funding from different funding sources in support of a common program or 

initiative. When aligned, each organization allocates and tracks expenditures for its 

own fund source(s) separately.

The Performance Partnership 

Pilots for Disconnected Youth 

(P3) initiative provides 

grantees with new flexibility, 

such as waivers for program or 

funding requirements, for using 

federal discretionary funds to 

test innovative service ideas to 

improve outcomes for 

opportunity youth. 

The federal agencies grouped the programs serving opportunity youth into three

categories, based on the likelihood that a waiver of funding requirements to allow 

blending would adversely affect vulnerable populations. The categories are:

1. Programs with low likelihood that blending funds would adversely affect youth 

services

2. Programs requiring significant review to ensure that blending funds wouldnot 

adversely affect youth

3. Programs likely inappropriate for blending funds.

The full list of identified programs from the earlier rounds of P3 pilots is included as 

Appendix A of this tool. Stakeholders can use Appendix A to determine if any of the 

funding currently being used for strategy implementation was categorized by the 

federal agencies. If yes, list the funding program source and category below. If 

stakeholders identify current strategy funding or support from a Category 1 program, 

the partners should explore opportunities to more efficiently leverage those resources 

by blending, braiding, or aligning with other available funds.
12

Opportunities to More Efficiently Leverage Category 1 Program Funds:

Next, stakeholders should consider what additional funding may be important for 

successfully implementing the identified strategy. While Appendix A may be a good 

source of federally-funded programs, stakeholders should also identify funding from 

sources such as philanthropic and nonprofit organizations, corporations, universities, 

and others. Use the space on the next page to list potential funding sources and the 

relevant category for any federal programs identified.

Source and Category of Potential 

Funds:

The Fiscal Mapping 

Resource Hub is a great 

resource for stakeholders 

who want to identify and 

coordinate the funds 

needed to achieve 

significant educational, 

workforce, and healthrelated goals. 

Along with a searchable 

tool detailing over 120 

programs across 7 

different federal agencies, 

the Hub includes case 

studies, a step-by-step 

over of the fiscal mapping 

process, and a related 

toolkit.
13

STEP 5: BARRIER IDENTIFICATION

Most discretionary funding programs for serving opportunity youth have established 

requirements for the use of funds, including eligibility thresholds, allowable activities, 

service timelines, and performance measures. Unfortunately, funding requirements 

often vary widely from program to program, which can lead to barriers that limit or 

restrict the ability of partners to blend, braid, and align resources effectively.

If the strategy cannot currently be implemented or 

accomplished effectively, stakeholders should 

identify the specific restrictions, limitations, or 

barriers that are preventing action on key strategy 

components.

Similar to Step 3, it is 

important to be as specific as 

possible when identifying 

restrictions and barriers.

- How does the barrier 

restrict or prevent your 

strategy-related actions?

- Who are you unable to 

serve?

- Are negative outcomes 

related to the restriction or 

barrier?

- Why is the barrier 

important?

Barrier 1:

Barrier 2:

Barrier 3:
14

 : 

STEP 6: BARRIERS ANALYSIS

In this step, stakeholders will analyze each of the barriers identified in Step 5. Print 

additional sheets as necessary. Rewrite the barrier being analyzed in the box below

Barrier # Given the complexity of some 

barriers, it may be helpful for 

stakeholders working on this step 

to connect with staff of the 

appropriate funding 

agency/agencies to better 

understand the source of policy, 

regulatory, and other restrictions. 

For example, the regional officer 

for the Employment and Training 

Administration in the U.S. 

Department of Labor can be an 

important contact for questions 

about the Title I WIOA Youth 

program and other Department of 

Labor workforce programs. Find 

your regional contact here: 

https://www.doleta.gov/regions/

Type of Barrier

The barrier identified above is specifically 

related to the following: [Select all that apply 

and detail in the space provided.]

□ Use of funds:

□ Eligibility requirements:

□ Definitions of eligible services:

□ Information-sharing rules:

□ Performance/Reporting requirements:

□ Conflicting policies:

_
15

□ Service timelines:

□ Other barrier:

Identifying the Source of the Barrier

A barrier may result from a statute, regulation, and/or policy developed by departments 

or agencies at multiple levels of government and by other organizations, depending on 

how the funding flows from its original source to the program level. An organization 

may be the funding source or originator, a pass through organization, an organization 

that awards subgrants or subcontracts, or have another role with regard to the funds 

prior to the end-user organization. The barrier might also be due to state or local 

interpretation of a policy or use of discretion in implementing a policy. In some cases, 

states or local areas may restrict local procurement or subcontracting of federal funds.

To identify the source of the barrier, it is important to identify all of the entities that are 

involved in the flow of funding and understand which are allowed to set funding 

requirements or other parameters that may create barriers to strategy implementation.

Which entities are involved in funding the program impacted by the barriersdescribed 

above? Is the entity allowed to set funding requirements or other relevant parameters? 

[Select all that apply.]

Entity Involved

with

funds? 

Involved

with funding 

restrictions

or other 

parameters?

Federal government department or agency:

Which office of this federal department or agency?

□ □

State-level or tribal-level department or agency:

Which office of the state or tribal department or 

agency?

□ □
16

Entity Involved Involved

with with funding 

funds? restrictions

or other 

parameters?

Local agency or department:

□ County:

□ City:

□ □

Other Authority (can be at multiple levels of 

government):

□ School Board

□ Housing Authority

□ WIOA/Workforce Board

□ Other

□ □

Other Funder Type:

□ Philanthropic organization

□ Nonprofit organization

□ Corporate/for-profit organization

□ Other private organization

□ □

Which entity identified above is primarily responsible for developing or enforcing the 

restriction or barrier to the strategy implementation?

Name any other entities that are also significantly responsible for developing or 

enforcing the restriction or barrier to the strategy implementation.
17

Identifying the Relevant Statute/ Regulation/ Policy

The stakeholders should then identify the 

relevant authority in statue, regulation, policy, 

or other guidance related to the funding barrier 

developed/enforced by the entity identified 

above as primarily responsible. Often, funding 

agencies and other entities post information on 

funding requirements, policies, and regulatory 

authority on their organizational website.

Funding agency staff may also be a good source 

of information.

Provide a specific citation where possible; this 

will help in future discussions about the barrier 

with funding staff and other officials, including 

the development of waiver requests and other 

solution options. [Select all that apply.]

It may be helpful for 

community leaders to write 

to the respective funding 

agencies with a list of 

policy-related questions or 

issues, and to ask for 

written responses to their 

policy queries. These 

responses can be used to 

spark important dialogue 

among partners.

Source of Authority

□ Statute:

□ Regulation:

□ Administrative memo/guidance:

□ Policy:

□ Funding requirement:

□ Other:

If more than one entity has developed or enforced its policy or regulatory authority in 

relation to the identified barrier, please document the details of those additional 

relevant restrictions in the space below.

Additional Relevant Statutes/Regulations/Policies:
18

STEP 7: IDENTIFYING SOLUTIONS

Potential Solutions

Are there some specific ways partners can work together to make a case for change or 

determine a solution within their discretionary authority? Stakeholders should identify 

opportunities to partner with other agencies or to align work in new ways to serve the 

target population in the absence of a specific waiver or policy change.

Explain:

Potential Waivers Needed

If there are no solutions that would significantly address the barrier, which partners 

could or should pursue a waiver request, and to which agency would the request be 

submitted? See Appendix B for waiver request examples from the P3 grants program.

Explain:

CONCLUSION

This tool is intended to help stakeholders articulate shared goals, identify barriers, and 

determine strategies to better serve opportunity youth in your communities. Collaboration 

across all levels of government, as well as among your many partners, is essential. We hope the 

solutions reached in Step 7 will provide stakeholders with needed actions steps for moving 

forward with their target strategies.
19

APPENDIX A: LIST OF PROGRAMS FROM 

THE ROUND 3 PERFORMANCE

PARTNERSHIP PILOT NOTICE OF 

INVITATION FOR APPLICATIONS

Source: https://youth.gov/youth-topics/reconnecting-youth/performance-partnershippilots/round-3-program-list

Category 1: Programs with Low Likelihood of Adversely Affecting Vulnerable 

Populations

The agencies have identified these programs as presenting a low likelihood of adversely 

affecting vulnerable populations if they are blended in a pilot. The agencies would 

require assurances, but not plans, for ensuring the protection of individuals and 

vulnerable populations in receiving services. These programs may align with the 

purpose or requirements of Performance Partnership Pilots, or they may have 

sufficiently broad authority so that blending those funds would be unlikely to violate the 

statutory protections.

Agency Program

Corporation for National and Community 

Service

AmeriCorps State Grants

Corporation for National and Community 

Service

Social Innovation Fund

Department of Education—Office of Career, 

Technical, and Adult Education

Adult Education and Family Literacy Act

Department of Education—Office of Career, 

Technical, and Adult Education

Carl D. Perkins Career and Technical Education Act

Department of Education—Office of 

Elementary and Secondary Education

21st Century Community Learning Centers

Department of Education—Office of Innovation 

and Improvement

Full Service Community Schools

Department of Education—Office of Innovation 

and Improvement

Promise Neighborhoods

Department of Education—Office of 

Postsecondary Education

Gaining Early Awareness and Readiness for 

Undergraduate Programs (GEAR UP)

Department of Education—Office of 

Postsecondary Education

TRIO—Talent Search

Department of Education—Office of 

Postsecondary Education

TRIO—Upward Bound

Department of Justice—Office of Juvenile 

Justice and Delinquency Prevention

Mentoring Opportunities for Youth Grants

Department of Labor—Employment and 

Training Administration

Workforce Innovation and Opportunity Act—Adult

Department of Labor—Employment and 

Training Administration

Workforce Innovation and Opportunity Act—Youth
20

Agency Program

Department of Labor—Employment and 

Training Administration

YouthBuild

Institute of Museum and Library Services Library Services and Technology Act Grants to State 

Library Administrative Agencies

Institute of Museum and Library Services Museums for America

Institute of Museum and Library Services Native American/Native Hawaiian Museum Services 

Program

Institute of Museum and Library Services Native American Library Services (Basic and 

Enhancement Grants)

Institute of Museum and Library Services Native Hawaiian Library Services

Institute of Museum and Library Services Museum Grants for African American History and 

Culture

Institute of Museum and Library Services Laura Bush 21st Century Librarian Program

Institute of Museum and Library Services National Leadership Grants for Museums/National 

Leadership Grants for Libraries

Category 2: Programs Requiring Significant Review to Ensure that Vulnerable 

Populations Are Not Adversely Affected

Federal agencies have identified these programs as potentially eligible for blending, but only with 

significant, robust safeguards in place to ensure vulnerable populations are not adversely affected. 

While applicants should propose safeguards as needed, these safeguards would ultimately be 

negotiated and finalized through the performance agreement. These programs typically serve highly 

vulnerable populations, such as homeless youth, foster youth, justice-involved youth, and students 

with disabilities.

To blend funds from such programs, applicants must convincingly demonstrate that the outcomes of 

the population served by the original program will not diminish during the pilot. Evidence may 

include plans for data collection on the vulnerable population(s), alternative service options, and 

alternative sources of funds. A pilot’s Performance Agreement may include outcome measurements 

and accountability mechanisms related to these vulnerable populations.

Agency Program

Department of Education—Office of 

Elementary and Secondary Education

Elementary and Secondary Education Act, Title I, Part A 

(Grants to Local Educational Agencies)

Department of Education—Office of Indian 

Education

Indian Education—Grants to Local Education Agencies

Department of Education—Office of Indian 

Education

Special Programs for Indian Children—Native Youth 

Community Projects

Department of Education—Office of Safe 

and Healthy Students

Elementary and Secondary Education Act, Title I, Part D 

(Neglected and Delinquent)

Department of Education—Office of Safe 

and Healthy Students

McKinney-Vento Education for Homeless Children and 

Youth Program

Department of Health and Human 

Services—Administration for Children and 

Families

Adolescent Pregnancy Prevention Program (APPP)

Department of Health and Human 

Services—Administration for Children and 

Families

Basic Centers Program (BCP-Runaway and Homeless 

Youth)
21

Agency Program

Department of Health and Human 

Services—Administration for Children and 

Families

Transitional Living Program (TLP—Maternity Group 

Home)

Department of Health and Human 

Services—Administration for Children and 

Families

Street Outreach Program (SOP-Runaway and Homeless 

Youth)

Department of Health and Human 

Services—Administration for Children and 

Families

Transitional Living Program (TLP—Runaway and 

Homeless Youth)

Department of Health and Human 

Services—Substance Abuse and Mental 

Health Services Administration

“Now Is The Time” Healthy Transitions (HT): Improving 

Life Trajectories For Youth And Young Adults With, Or At 

Risk For, Serious Mental Health Conditions

Department of Health and Human 

Services—Substance Abuse and Mental 

Health Services Administration

State Youth Treatment (SYT) Cooperative Agreements

Department of Housing and Urban 

Development—Office of Special Needs 

Assistance Programs

Continuum of Care (CoC) Program

Department of Housing and Urban 

Development—Office of Special Needs 

Assistance Programs

Emergency Solutions Grant (ESG) Program

Department of Justice—Office of Juvenile 

Justice and Delinquency Prevention

Drug Court Program

Department of Justice—Office of Juvenile 

Justice and Delinquency Prevention

Family Court Program

Department of Justice—Office of Juvenile 

Justice and Delinquency Prevention

Second Chance Act: Strengthening Relationships 

between Young Fathers and their Children

Department of Justice—Office of Juvenile 

Justice and Delinquency Prevention

Second Chance Act: Supporting Latino/a Youth from 

Out-of-Home Placement to the Community

Department of Justice—Office of Juvenile 

Justice and Delinquency Prevention

Title II Formula Grant Program

Department of Justice—Office of Juvenile 

Justice and Delinquency Prevention

Smart on Juvenile Justice: Reducing Out-of-Home 

Placement Program

Department of Labor—Employment and 

Training Administration

Reintegration of Ex-Offenders

Department of Labor—Employment and 

Training Administration

Workforce Innovation and Opportunity Act Section 166 

Indian and Native American Youth Program

Department of Labor—Employment and 

Training Administration

Workforce Innovation and Opportunity Act Section 167 

National Farmworker Jobs Program

Category 3: Programs Likely Inappropriate for Pilots Due to High Likelihood of 

Restricting Eligibility for Services or Adversely Affecting Vulnerable Populations

While case-by-case determinations will be made, the agencies have determined there is 

a strong likelihood that blending funds from these programs would: (1) deny or restrict 

an individual’s eligibility for services funded by these programs; or (2) adversely affect 

vulnerable populations that receive such services. These programs may entitle all 

eligible individuals to a service or provide individuals with direct benefits, such as
22

vouchers, credits, and scholarships. Applicants can try to justify that the blending of 

programs’ funds would not violate the P3 statutory protections. Such justifications must 

be compelling.

Agency Program

Department of Health and Human Services—

Administration for Children and Families

Chafee Education and Training Vouchers

Department of Health and Human Services—

Administration for Children and Families

Promoting Safe and Stable Families, Title IV-B, 

Subpart 2 (discretionary appropriations only)

APPENDIX B: EXAMPLES OF WAIVERS 

APPROVED FROM THE FIRST THREE ROUNDS

OF THE PERFORMANCE PARTNERSHIP PILOT 

GRANT PROGRAM

• Allow 21st Century Community Learning Center funds to be used to support 

authorized activities during the school day. Permit 21st Century Community 

Learning Center funds to be used to support transition coordinators to work with 

youth who are not enrolled in school to help them resume their educations.

• Waive the limitation on serving individuals older than age 21 in targeted assistance 

programs authorized by Title I, Part A of the Elementary and Secondary Education 

Act.

• Permit Gaining Early Awareness and Readiness for Undergraduate Programs

(GEAR UP) funds to be used not only to provide a seventh year of service to 

students during their first year of attendance at an institution of higher education, 

but also to provide a seventh year of service to students who did not enroll at an 

institution of higher education during their first year after exiting high school.

• Increase the eligibility age from 21 to 24 for homeless youth in the Transitional 

Living Program, provided that the number of younger youth participants (ages 16-

21) served is not reduced. 

• Waive statutory performance measures for the Workforce Innovation and 

Opportunity Act Title I Youth program and use proposed alternative measures 

instead. 

• Allow foster care, homeless, and runaway youth who are in school to be counted in 

the 75 percent out-of-school youth service category for the Workforce Innovation 

and Opportunity Act Title I Youth program for fiscal accounting purposes and for 

the youth participating in the pilot only. 

• Allow the pilot to consider foster care and homeless youth participating in the pilot 

to be eligible participants under the 10 percent exemption in the Reentry

Employment Opportunities program. Blend funds from the Workforce Innovation 

and Opportunity Act Title I Youth program, with funds from Gaining Early 
23

Awareness and Readiness for Undergraduate Programs (GEAR UP) and Full 

Service Community Schools grants

• Blend funds from the Workforce Innovation and Opportunity Act Title I Youth 

program with funds from the 21st Century Community Learning Centers program. 

APPENDIX C: OTHER RESOURCES

The Fiscal Mapping Resource Hub is a collection of resources that communities can 

leverage to identify and coordinate the funds needed to achieve significant educational, 

workforce, and health-related goals. These include a fiscal mapping tool, a step-by-step 

overview, a toolkit for working with partner organizations, and case studies.

Youth.gov is a website maintained by the federal government to help organizations

serving youth. Included on the website are “youth facts, funding information, and tools 

to help you assess community assets, generate maps of local and federal resources, 

search for evidence-based youth programs, and keep up-to-date on the latest, youthrelated news.”