[Federal Register Volume 60, Number 96 (Thursday, May 18, 1995)]
[Notices]
[Pages 26812-26821]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-12332]



      

[[Page 26811]]

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Part VI





Department of Labor

_______________________________________________________________________



Employment and Training Administration





  





  





Department of Education





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Office of Vocational and Adult Education; School-to-Work Opportunities 
Act; State Implementation Grants; Notice

Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / 
Notices

[[Page 26812]]

DEPARTMENT OF LABOR

Employment and Training Administration

DEPARTMENT OF EDUCATION


Office of Vocational and Adult Education; School-to-Work 
Opportunities Act; State Implementation Grants

AGENCIES: Department of Labor and Department of Education.

ACTION: Notice Inviting Applications for New Awards for Fiscal Year 
(FY) 1995 and Notice of final selection criteria and a definition of 
administrative costs for School-to-Work Opportunities State 
Implementation Grants (State Implementation Grants) to be made in 
fiscal year 1995 and in succeeding years.

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SUMMARY: The Departments of Labor and Education jointly invite 
applications for new awards in FY 1995. The Departments also announce 
final selection criteria to be used in evaluating applications 
submitted under the State Implementation Grants competition in FY 1995 
and in succeeding years, authorized under section 212 of the School-to-
Work Opportunities Act of 1994 (the Act). State Implementation Grants 
will enable States to implement their plans for statewide School-to-
Work Opportunities systems. Such systems will offer young Americans 
access to programs designed to prepare them for a first job in high-
skill, high-wage careers, and for further education and training. The 
Departments also announce a definition for the term ``administrative 
costs'' that will apply to State Implementation Grants funded under the 
Act.

DATES: The closing date for receipt of applications is June 19, 1995.

SUPPLEMENTARY INFORMATION:

Background

    The Departments of Labor and Education are reserving funds 
appropriated for FY 1995 under the Act (Pub. L. 103-329) for a 
competition for State Implementation Grants authorized under section 
212 of the Act.
    This notice contains a definition of the term ``administrative 
costs'' and the selection criteria that will be used in evaluating 
applications submitted in response to this year's competition.

Invitation for Application for New Awards

    Purpose of Program: These funds will serve as ``venture capital'' 
to allow States to build comprehensive School-to-Work Opportunities 
systems which provide all youth with high-quality education that 
integrates school-based learning, work-based learning and connecting 
activities, prepares young Americans for success in high-skill, high-
wage careers, and increases their opportunities for further education 
and training.
    Eligible Applicants: All States that did not receive a State 
Implementation Grant in FY 1994, the District of Columbia, and Puerto 
Rico are eligible for Implementation Grants under this competition. In 
accordance with the School-to-Work Opportunities Act, the Governor must 
submit the application on behalf of the State.
    Deadline for Transmittal of Applications: The closing date for 
receipt of applications is June 19, 1995, at 2 p.m. (Eastern Time). 
Telefacsimile (FAX) applications will not be honored.
    Availability of Applications: Application packages will be mailed 
directly to both the Governor and the State School-to-Work Development 
Grant contact of each eligible applicant, as listed above. Applications 
will be mailed to applicants, via overnight mail, within one day of the 
publication of this notice in the Federal Register. Any other party 
interested in receiving a copy of the application package should 
contact: School-to-Work Office, 400 Virginia Avenue, S.W., Room 100-C, 
Washington, D.C. 20024. Telephone: (202) 401-6222.
    Available Funds: Approximately $86,000,000 (funding for the first 
twelve months).
    Estimated Range of Awards: The Departments expect the minimum award 
to be approximately $1.5 million and the maximum award to be 
approximately $20 million. The Departments wish to emphasize that, in 
accordance with sections 212, 213, 214, and 216 of the Act, the actual 
amount of each award made under this competition will depend on such 
factors as the scope and quality of the State plan and application, the 
number of projected participants in programs operating within each 
State's School-to-Work Opportunities system, and the State's youth 
population. Therefore, the Departments strongly encourage applicants to 
consider these factors, the estimated average grant award amount, and 
the amount of awards made to the first eight Implementation States in 
deciding what funds to request. Applicants are discouraged from 
requesting significantly more funds than States with similar numbers of 
school-age youth received last year without a strong programmatic basis 
for doing so. (Information on last year's awards is contained in the 
application package.)
    Estimated Average Size of Awards: $4.5 million.
    Estimated Number of Awards: Up to 20.

    Note: The Departments are not bound by any estimates in this 
notice.

    Project Period: Up to 5 years (5 twelve-month grant periods).
    Applicable Regulations: 29 CFR Parts 33, 93, 95, 96, 97, 98. The 
selection criteria and definition published in this notice, as well as 
the instructions contained in the application package and the 
eligibility and other requirements specified in the Act, apply to this 
competition.
    For Additional Information Contact: Ms. Laura Cesario, U.S. 
Department of Labor, Employment and Training Administration, Division 
of Acquisition and Assistance, 200 Constitution Avenue NW., Room S-
4203, Washington, D.C. 20210. Telephone: (202) 219-7300, extension 21 
(this is not a toll-free number). Individuals who use a 
telecommunications device for the deaf (TDD) may call the Federal 
Information Relay Service (FIRS) at 1-800-877-8339 between 8 a.m. and 8 
p.m., Eastern time, Monday through Friday.
    Reference: SGA # DAA--007.

Implementation Grant Competition

Analysis of Comments and Changes

    On March 10, 1995, the Departments of Labor and Education published 
a notice of proposed selection criteria and a proposed definition of 
the term ``administrative costs'' for this competition and competitions 
in succeeding years in the Federal Register (60 FR 13312-13315). In 
response to the invitation to comment, 55 parties submitted comments. 
An analysis of the comments received in response to the publication of 
that notice and of the changes made to the selection criteria and 
definition since publication of the notice of proposed criteria and 
proposed definition is published as an appendix to this notice.

School-to-Work Opportunities State Implementation Grants

Definition
    All definitions in the Act apply to School-to-Work Opportunities 
systems funded under this and future State Implementation Grant 
competitions. Since the Act does not contain a definition of the term 
``administrative costs'' as used in section 217 of the Act, the 
Departments will apply the following definition to this and future 
[[Page 26813]] competitions for State Implementation Grants:
    The term ``administrative costs'' means the activities of a State 
or local partnership that are necessary for the proper and efficient 
performance of its duties under the School-to-Work Opportunities Act 
and that are not directly related to the provision of services to 
participants or otherwise allocable to the system's allowable 
activities listed in section 215(b)(4) and section 215(c) of the Act. 
Administrative costs may be either personnel costs or non-personnel 
costs, and direct or indirect. Costs of administration shall include, 
but not be limited, to:
    A. Costs of salaries, wages, and related costs of the grantee's 
staff engaged in:
    <bullet> Overall system management, system coordination, and 
general administrative functions;
    <bullet> Preparing program plans, budgets, and schedules, as well 
as applicable amendments;
    <bullet> Monitoring of local initiatives, pilot projects, 
subrecipients, and related systems and processes;
    <bullet> Procurement activities, including the award of specific 
subgrants, contracts, and purchase orders;
    <bullet> Developing systems and procedures, including management 
information systems, for assuring compliance with the requirements 
under the Act;
    <bullet> Preparing reports and other documents related to the Act; 
and
    <bullet> Coordinating the resolution of audit findings.
    B. Costs for goods and services reqiured for administration of the 
system;
    C. Costs of system-wide management functions; and
    D. Travel costs incurred for official business in carrying out 
grant management or administrative activities.
Selection Criteria
    Under the School-to-Work Opportunities Implementation Grant 
competition, the Departments will use the following selection criteria 
in evaluating applications and will utilize a two-phase review process. 
In the first phase, review teams, including peers, will evaluate 
applications using the selection criteria and the associated point 
values. In the second phase, review teams, including peers, will visit 
high-ranking States to gain additional information and further assess 
State plans. The following selection criteria will apply to both review 
phases. The Departments will base final funding decisions on 
information obtained during the site visits, the ranking of 
applications as a result of the first-phase review, and such other 
factors as replicability, sustainability, innovation, and geographic 
balance and diversity of program approaches.

 Selection Criterion 1: Comprehensive Statewide System

    Points: 35.
    Considerations: In applying this criterion, reviewers will 
consider:
    A. 20 points. The extent to which the State has designed a 
comprehensive statewide School-to-Work Opportunities plan that--
    <bullet> Includes effective strategies for integrating school-based 
and work-based learning, integrating academic and vocational education, 
and establishing linkages between secondary and postsecondary 
education;
    <bullet> Is likely to produce systemic change in the way youth are 
educated and prepared for work and for further education, across all 
geographic areas of the State, including urban and rural areas, within 
a reasonable period of time.
    <bullet> Includes strategic plans for effectively aligning other 
statewide priorities, such as education reform, economic development, 
and workforce development into a comprehensive system that includes the 
School-to-Work Opportunities system and support its implementation at 
all levels--State, regional and local;
    <bullet> Ensures that all students will have a range of options, 
including options for higher education, additional training and 
employment in high-skill, high-wage jobs; and
    <bullet> Ensures coordination and integration with existing local 
education and training programs and resources, including those School-
to-Work Opportunities systems established through local partnership 
grants and Urban/Rural Opportunities grants funded under Title III of 
the School-to-Work Opportunities Act, and related Federal, State, and 
local programs.
    B. 15 points. The extent to which the State plan demonstrates the 
State's capability to achieve the statutory requirements and to 
effectively put in place the system components in Title I of the 
School-to-Work Opportunities Act, including--
    <bullet> The work-based learning component that includes the 
statutory mandatory activities and that contributes to the 
transformation of workplaces into active learning components of the 
education system through an array of learning experiences, such as 
mentoring, job-shadowing, unpaid work experiences, school-sponsored 
enterprises, supported work experiences, and paid work experiences;
    <bullet> The school-based learning component that will provide 
students with high level academic skills consistent with academic 
standards that the State establishes for all students, including, where 
applicable, standards established under the Goals 2000: Educate America 
Act:
    <bullet> A connecting activities component to provide a functional 
link between students' school and work activities and employers and 
educators; and
    <bullet> A plan for an effective process for assessing students' 
skills and knowledge required in career majors, and the process for 
issuing portable skill certificates that are benchmarked to high 
quality standards such as those the State establishes under the Goals 
2000: Educate America Act, and for periodically assessing and 
collecting information on student outcomes, as well as a realistic 
strategy and timetable for implementing the process.

Selection Criterion 2: Commitment of Employers and Other Interested 
Parties

    Points: 15.
    Considerations: In applying this criterion, reviewers will 
consider:
    <bullet> The extent to which the State has obtained the active 
involvement of employers and other interested parties listed in section 
213(d)(5) of the Act, such as locally elected officials, secondary 
schools and postsecondary educational institutions (or related 
agencies), business associations, industrial extension centers, 
employees, labor organizations or associations of such organizations, 
teachers, related services personnel, students, parents, community-
based organizations, rehabilitation agencies and organizations, 
registered apprenticeship agencies, local vocational educational 
agencies, vocational student organizations, State or regional 
cooperative education associations, and human service agencies, as well 
as State legislators.
    <bullet> Whether the State plan demonstrates an effective and 
convincing strategy for continuing the involvement of employers and 
other interested parties in the statewide system, such as the parties 
listed in section 213(d)(5) of the Act, as well as State legislators.
    <bullet> The extent to which the State plan proposes to include 
private sector representatives as joint partners with educators in the 
oversight and governance of the overall School-to-Work Opportunities 
system. [[Page 26814]] 
    <bullet> The extent to which the State has developed strategies to 
provide a range of opportunities for employers to participate in the 
design and implementation of the School-to-Work Opportunities system, 
including membership on councils and partnerships; assistance in 
setting standards, designing curricula and determining outcomes; 
providing worksite experience for teachers; helping to recruit other 
employers; and providing worksite learning activities for students, 
such as mentoring, job-shadowing, unpaid work experiences, supported 
work experiences, and paid work experiences.

Selection Criterion 3: Participation of All Students

    Points: 15.
    Considerations: In applying this criterion, reviewers will refer to 
the definition of the term ``all students'' in section 4(2) of the Act 
and consider:
    <bullet> The extent to which the State will implement effective 
strategies and systems: to provide all students with equal access to 
the full range of program components specified in sections 102 through 
104 of the Act and related activities such as recruitment, enrollment 
and placement activities; and to ensure that all students have 
meaningful opportunities to participate in School-to-Work Opportunities 
programs.
    <bullet> Whether the plan identifies potential barriers to the 
participation of any students, and the degree to which the plan 
proposes effective ways of overcoming these barriers.
    <bullet> The degree to which the State has developed realistic 
goals and methods for assisting young women to participate in School-
to-Work Opportunities programs leading to employment in high-
performance, high-paying jobs, including nontraditional jobs and has 
developed realistic goals to ensure an environment free from racial and 
sexual harassment.
    <bullet> The feasibility and effectiveness of the State's strategy 
for serving students from rural communities with low population 
densities.
    <bullet> The State's methods for ensuring safe and healthy work 
environments for students, including strategies for encouraging schools 
to provide students with general awareness training in occupational 
safety and health as part of the school-based learning component, and 
for encouraging employers to provide risk-specific training as part of 
the work-based learning component.

    Note: Experience with the FY 1994 School-to-Work Opportunities 
State Implementation Grant applications has shown that many 
applicants do not give adequate attention to designing programs that 
will serve school dropouts and programs that will serve students 
with disabilities. Therefore, the Departments would like to remind 
applicants that reviewers will consider whether an application 
includes strategies to specifically identify the barriers to 
participation of dropouts and students with disabilities and 
proposes specific methods for effectively overcoming such barriers 
and for integrating academic and vocational learning, integrating 
work-based learning and school-based learning, and linking secondary 
and postsecondary education for dropouts and students with 
disabilities. Applicants are reminded that JTPA Title II funds may 
be used to design and provide services to students who meet the 
appropriate JTPA eligibility criteria.

Selection Criterion 4: Stimulating and Supporting Local School-to-Work 
Opportunities Systems

    Points: 15.
    Considerations: In applying this criterion, reviewers will 
consider:
    <bullet> The effectiveness of the State's plan for ensuring that 
local partnerships include employers, representatives of local 
educational agencies and local postsecondary educational institutions 
(including representatives of area vocational education schools, where 
applicable), local educators (such as teachers, counselors, or 
administrators), representatives of labor organizations or 
nonmanagerial employee representatives, and students, and others such 
as those included in section 4(11)(B).
    <bullet> The extent to which the State assists local entities to 
form and sustain effective local partnerships serving communities in 
all parts of the State.
    <bullet> Whether the plan includes an effective strategy for 
addressing the specific labor market needs of localities that will be 
implementing School-to-Work Opportunities systems.
    <bullet> The effectiveness of the State's strategy for building the 
capacity of local partnerships to design and implement local School-to-
Work Opportunities systems that meet the requirements of the Act.
    <bullet> The extent to which the State will provide a variety of 
assistance to local partnerships, as well as the effectiveness of the 
strategies proposed for providing this assistance, including such 
services as: Developing model curricula and innovative instructional 
methodologies, expanding and improving career and academic counseling 
services, and assistance in the use of technology-based instructional 
techniques.
    <bullet> The effectiveness of the State's strategy for providing 
staff development to teachers, employers, mentors, counselors, related 
services personnel, and others who are critical to successful 
implementation of School-to-Work Opportunities systems for all youth.
    <bullet> The ability of the State to provide constructive 
assistance to local partnerships in identifying critical and emerging 
industries and occupational clusters.

Selection Criterion 5: Resources

    Points: 10.
    Considerations: In applying this criterion, reviewers will 
consider:
    <bullet> The amount and variety of other Federal, State, and local 
resources the State will commit to implementing its School-to-Work 
Opportunities plan, as well as the specific use of these funds, 
including funds for JTPA Summer and Year-Round Youth programs and 
Perkins Act programs.
    <bullet> The feasibility and effectiveness of the State's long-term 
strategy for using other resources, including private sector resources, 
to maintain the statewide system when Federal resources under the 
School-to-Work Opportunities Act are no longer available.
    <bullet> The extent to which the State is able to limit 
administrative costs in order to maximize the funds spent on the 
delivery of services to students, as required in section 214(b)(3)(B) 
of the Act, while ensuring the efficient administration of the School-
to-Work Opportunities system.

Criterion 6: Management Plan

    Points: 10.
    Considerations: In applying this criterion, reviewers will 
consider:
    <bullet> The adequacy of the management structure that the State 
proposes for the School-to-Work Opportunities system.
    <bullet> The extent to which the State's management plan 
anticipates barriers to implementation and proposes effective methods 
for addressing barriers as they arise.
    <bullet> Whether the application includes an evaluation plan 
containing feasible, measurable goals for the School-to-Work 
Opportunities system, based on performance measures contained in 
section 402(a) of the Act.
    <bullet> The extent to which the evaluation plan includes an 
effective method for collecting information relevant to the State's 
progress in meeting its goals, and is likely to assist the State to 
meet its School-to-Work Opportunities system objectives, to gauge the 
success of the system in achieving those objectives, to continuously 
improve the system's effectiveness, and to contribute to the review of 
results across all States.
    <bullet> Whether the plan includes a feasible workplan for the 
School-to-Work Opportunities system that [[Page 26815]] includes major 
planned objectives over a five-year period.
Additional Priority Points

    As required by section 214(a)(1) and (a)(2) of the Act, the 
Departments will give priority to applications that demonstrate the 
highest level of concurrence among State partners with the State plan, 
and to applications that require paid, high quality work-based learning 
experiences as an integral part of the School-to-Work Opportunities 
system by assigning additional points--above the 100 points described 
in the criteria--as follows:
    1. Highest Levels of Concurrence--5 Points
    Up to 5 points will be awarded to applications that can--
    <bullet> Fully demonstrate that each of the State partners listed 
in section 213(b)(4) concurs with the State School-to-Work 
Opportunities plan, and that the State partners' concurrence is backed 
by a commitment of time and resources to implement the plan.
    2. Paid, High-Quality Work-Based Learning--10 Points
    Up to 10 points will be awarded to applications that demonstrate 
that the State--
    <bullet> Has developed effective plans for requiring, to the 
maximum extent feasible, paid, high-quality work experience as an 
integral part of the State's School-to-Work Opportunities system, and 
for offering the paid, high-quality work experiences to the largest 
number of participating students as is feasible; and
    <bullet> Has established methods for ensuring consistently high 
quality work-based learning experiences across the State.

    Program Authority: 20 U.S.C. 6101 et seq.

    Dated: May 15, 1995.
Doug Ross,
Assistant Secretary for Employment and Training, Department of Labor.
Augusta Kappner,
Assistant Secretary for Vocational and Adult Education, Department of 
Education.

Appendix--Analysis of Comments and Changes

Definition of Administrative Costs

    Comment: Three commenters suggested that public relations and 
evaluation were functions so central to the States' ability to 
implement systemic change that they should be excluded from the 
definition of administrative costs. One of the commenters also 
recommended excluding monitoring and developing systems for assuring 
compliance, for the same reason. One of these commenters suggested 
that first-year costs to establish these activities might be 
excluded, while maintaining the activities in future years could be 
charged to administrative costs.
    Discussion: The Departments agree that marketing (referred to as 
``public relations'' in the notice of proposed selection criteria) 
and evaluation are key State system-building functions. Developing 
and maintaining a comprehensive statewide system will require change 
on the part of a great many organizations and individuals and the 
development of extensive partnerships at the State and local levels. 
Communicating the need for such change and challenging different 
groups to get involved--marketing--is an activity that is essential 
to achieving a School-to-Work Opportunities system. In addition, the 
evaluation function is especially critical because of the need for 
an ongoing process of measuring system effectiveness. The 
Departments believe, however, that monitoring and establishing 
compliance systems are activities more appropriately charged to the 
administrative cost category. The Departments expect that States 
will be providing extensive assistance to local partnerships to 
build their capacity to develop and implement local School-to-Work 
systems that meet the requirements of Title I. This process of 
forming and sustaining partnerships, which is addressed under 
Criterion 4, should be designed to help prevent compliance problems.
    Changes: The activities related to marketing and evaluation 
against stated objectives have been deleted from the list of 
activities that must be included in the administrative cost 
category.

Restructuring Criteria

    Comment: One commenter suggested restructuring the six criteria 
around the two major responsibilities of a State under School-to-
Work Opportunities: (1) Developing and guiding a comprehensive 
statewide system; and (2) supporting the local School-to-Work 
Opportunities system. This commenter also recommended that the areas 
for which additional points could be awarded (``Highest Levels of 
Concurrence'' and ``Paid, High-Quality Work Experience'') should, 
instead, be incorporated into one of the other criteria.
    Discussion: The Departments agree that distributing the criteria 
around the two major responsibilities identified might be a useful 
alternative way to structure the criteria. However, other than 
repositioning the bullets, the recommendation did not include 
changing or deleting any of the bullets. In addition, the 
Departments do not agree that the areas for which additional points 
may be awarded could be incorporated into one of the selection 
criteria. Section 214 of the School-to-Work Opportunities Act of 
1994 (the Act) requires that priority be given to applications that 
demonstrate the highest levels of concurrence among State partners 
and to applications that require paid, high-quality work experience. 
Subsuming these areas within other selection criteria is not 
consistent with the priority required by the Act. On balance, the 
Departments are confident that the current structure of the 
selection criteria adequately reflects the elements of a 
comprehensive State School-to-Work Opportunities system.
    Changes: None.

Selection Criterion 1: Comprehensive Statewide System (A)

Postsecondary Involvement

    Comment: One commenter stated that the criteria did not address 
possible duplication of effort between School-to-Work Opportunities 
systems and programs established in public educational institutions, 
such as local community colleges. This commenter was concerned that 
localities might limit community college involvement, while favoring 
programs funded under the Department of Labor's Job Training 
Partnership Act. The commenter stated that the notice should include 
points for applications that promote the participation of local 
postsecondary institutions and community colleges, and also ``should 
address local secondary school participation.''
    Discussion: The School-to-Work initiative is designed to unify 
categorical programs into coherent and comprehensive systems, and 
the Departments believe that the law and the notice adequately 
address duplication of effort. Coordination with, and integration of 
existing programs, including those in place in community colleges, 
is a key feature of School-to-Work Opportunities systems. An 
approved State plan must include strategies for effectively linking 
secondary and postsecondary education and the plan must describe 
coordination with programs funded under a range of authorities, 
including the Adult Education Act, the Perkins Act, the Elementary 
and Secondary Education Act (ESEA), and the Higher Education Act 
(see section 213(d)(6) of the Act). State partnerships must include 
State agency officials responsible for postsecondary education, and 
the notice awards priority points to applications that demonstrate 
partners' full concurrence with the School-to-Work Opportunities 
plan. Under Criterion 2: ``Commitment of Employers and Other 
Interested Parties,'' applicants must describe the State's efforts 
to obtain and maintain the substantive participation of a range of 
stakeholders. In response to several comments, Criterion 2 has been 
changed to explicitly list the examples of interested parties as 
given in section 213(d)(5) of the Act, including secondary schools 
and postsecondary educational institutions, so that applicants are 
reminded of the range of organizations that might contribute to the 
effectiveness of the School-to-Work Opportunities system. Also in 
response to comments, Selection Criterion 4: ``Stimulating and 
Supporting Local School-to-Work Opportunities Systems'' now lists 
the required members of local partnerships as given in the Act, 
including local educational agencies and local postsecondary 
institutions, and applications must show how the State will assist 
communities in developing effective local partnerships. Given these 
specifications, the final notice makes it more explicit that only 
applications that demonstrate the genuine involvement of local 
secondary schools, community colleges, and other postsecondary 
institutions in their School-to-Work systems, will be competitive. 
While the Departments support State and [[Page 26816]] local 
flexibility in deciding which networks form the most appropriate 
base from which to expand School-to-Work Opportunities systems, the 
Departments also believe it is highly unlikely that an effective 
system can be built with only limited, selective participation of 
the stakeholders mentioned in the Act. In response to the comment 
about the need to address local secondary school participation, the 
Departments wish to stress that any application that under Criterion 
1 B fails to present a convincing plan for institutional change in 
secondary schools statewide, will not be competitive.
    Changes: None.

Preparation for Entry Into Four-Year Colleges

    Comment: One commenter was concerned that comprehensive School-
to-Work Opportunities systems would be associated with vocational 
education; the commenter believed vocational education is negatively 
viewed as yielding few academic skills, limiting postsecondary 
options, and limiting access to careers that require postsecondary 
education. The commenter believed that Criterion 1 should require 
reviewers to consider the extent to which plans ensure that all 
students graduating from secondary school will be ``eligible'' to 
enter four-year colleges.
    Discussion: School-to-Work Opportunities systems must prepare 
learners for a range of education, employment and training options, 
as discussed throughout the Act and highlighted in the notice of 
proposed selection criteria in the first, second and fourth bullets 
of Criterion 1. School-to-Work aims at developing a lifelong 
continuum of learning and work experience, rather than targeting a 
specific type of institution or course of study. The Departments 
agree with the commenter on the need to emphasize to parents, 
students, and other stakeholders that School-to-Work Opportunities 
systems will not limit, but rather enhance, all students' capacity 
to master concepts and successfully enter and complete four-year 
degree programs. Since they utilize new methods of teaching, 
learning, assessing and demonstrating student achievement, School-
to-Work Opportunities systems will also require flexibility and 
support from employers and four-year institutions for new methods of 
measuring student performance, such as skill certificates and 
portfolios. Although the Departments do not believe that a specific 
reference to ``eligibility'' for four-year colleges is necessary, 
they wish to stress that the success of student transitions will 
depend in part on the commitment of employers and postsecondary 
institutions to develop and accept new measures of student 
performance resulting from educational reform.
    Changes: None.

K-Adult Continuum

    Comment: One commenter suggested that language be added to 
support a State School-to-Work Opportunities plan that addresses all 
students, from K-Adult.
    Discussion: The Departments believe that the criteria, as 
written, address life-long learning in many respects. Reviewers will 
evaluate the extent to which a State's implementation plan 
integrates education and training programs and resources, including 
those which serve adults, such as postsecondary, continuing 
education, existing worker training and registered apprenticeship 
programs. Also, the Departments expect that a State's partnership 
will include a range of entities (see sections 213(b)(4) and 
213(d)(5) of the Act), many of which relate directly to adult 
learners and workers. Finally, the most comprehensive plans for 
education reform will be strongly tied to related statewide 
initiatives such as economic development and workforce development, 
with School-to-Work as the framework for a K-Life continuum. 
Therefore, the Departments anticipate that the most competitive 
applications will address life-long learning implicitly in the 
implementation plan, or will achieve this integration in the long 
term.
    Changes None.

Focus on Communities With High Concentrations of Poor and 
Disadvantaged Youth

    Comment: One commenter suggested that the second bullet of 
Criterion 1 A, which refers to the State's plan for systemic change, 
include specific mention of communities with high concentrations of 
poor and disadvantaged youth.
    Discussion: The Departments believe that Criterion 1 A, by 
considering the extent to which the School-to-Work Opportunities 
system is likely to encompass and produce change in all areas 
statewide, addresses the inclusion of communities with high 
concentrations of poor and disadvantaged youth. Applications that do 
not outline convincing strategies and timelines for achieving 
comprehensive statewide coverage will be less competitive than those 
that do. In addition, the second bullet in the now-revised Criterion 
4 places further weight on the State's plan to actively assist local 
partnerships in expanding the system to reach communities in all 
parts of the State. Reviewers will evaluate whether there are gaps 
in the strategy for implementing the School-to-Work Opportunities 
system throughout the State and score the application accordingly.
    Changes: None.

Apprenticeship Training

    Comment: One commenter expressed the view that apprenticeship 
training be included in Criterion 1 A with education reform, 
economic development, and workforce development, as statewide 
priorities in the establishment of a comprehensive system. The 
commenter also believed that the work-based learning component in 
Criterion 1 B should include, as a potential learning experience, 
early entry into apprenticeship training.
    Discussion: In Criterion 1, ``education reform,'' ``economic 
development,'' and ``workforce development'' are broad terms that 
are intended to include a variety of programs and activities that 
may be part of a State's strategic priorities. The Departments 
believe that apprenticeship training is likely to be a key component 
in many comprehensive workforce development strategies; however, 
they do not want to suggest that any specific program must be part 
of a State's workforce development initiative. In regard to the 
suggestion that early entry into apprenticeship training be included 
in the bullet on work-based learning on Criterion 1 B, the 
Departments agree that early entry into an apprenticeship program 
can be an appropriate objective for a School-to-Work Opportunities 
program. Section 215(b) (4) (K) of the Act includes, as an allowable 
activity for local partnerships receiving subgrants from States, the 
creation or expansion of school-to-apprenticeship programs in 
cooperation with registered apprenticeship agencies and 
apprenticeship sponsors. However, the extent to which apprenticeship 
training is utilized as a work-based learning experience in a 
statewide system is most suitably determined by the State.
    Changes: None.

System Change for Youth With Disabilities

    Comment: Several commenters recommended requiring special plans 
to demonstrate how School-to-Work Opportunities programs will be 
coordinated with ``systems change grants'' and other related 
activities under the Individuals with Disabilities Education Act 
(IDEA). In order to ensure participation by youth with disabilities, 
these commenters suggested that Criterion 1 A be revised to 
specifically reference IDEA transition projects or Systems Change 
for Youth with Disabilities.
    Discussion: Achieving comprehensive reform will require States 
to coordinate and integrate a great number and variety of State 
initiatives having related goals. The Departments agree that the 
lessons learned from initiatives and programs that are related to 
School-to-Work should be incorporated into the State's comprehensive 
plan. The fifth bullet under Criterion 1 A is intended to encourage 
States to review the many related Federal, State and local programs 
and initiatives and develop strategies for creating mutually 
supportive strategies.
    Changes: None.

Selection Criterion 1: Comprehensive Statewide System (B)

Emphasis on Coordination With Goals 2000

    Comment: Several commenters expressed concern about the 
relationship between School-to-Work and the Goals 2000: Educate 
America Act. The commenters emphasized the voluntary nature of 
States' participation in Goals 2000 activities, and believed that 
the notice linked academic and skills standards too closely to these 
activities rather than focusing more broadly on statewide education 
reform initiatives. Conversely, one commenter stated that the 
criteria did not highlight strongly enough the importance of the 
State's role in developing curricula and instructional methodologies 
consistent with academic and skill standards such as those 
established under Goals 2000, nor in ensuring that students achieve 
these standards. One commenter noted that the use of the past tense 
in referring to standards ``established'' under Goals 2000 implies 
that States have submitted standards for certification by The 
National Education [[Page 26817]] Standards and Improvement Council. 
(The Council is provided for under Goals 2000, but has not been 
formed.) One commenter believed that the Goals 2000 standards apply 
only to traditional academic subject areas, disregarding core 
standards and performance measures for vocational and technical 
education already being developed by States under the Perkins Act, 
and separating academic performance from performance related to 
workforce-development. This commenter stated that a reference in 
Criterion 2 to employer involvement in the development of standards 
was the only linkage to the performance-based system being built 
under the Perkins Act.
    Discussion: The Departments wish to clarify that participation 
in activities under both Goals 2000 and School-to-Work is strictly 
voluntary, and that participation in Goals 2000 is in no way a 
condition for receiving a School-to-Work Opportunities 
Implementation Grant. However, in the case of States that have 
chosen to participate in Goals 2000, the Departments will consider 
whether plans developed under School-to-Work and Goals 2000 are 
coordinated and mutually reinforcing. A major focus of Criterion 1 
is the need to integrate School-to-Work into the State's overall 
agenda for education reform or restructuring. The Departments intend 
to emphasize the need for high, statewide standards against which to 
develop curriculum, measure the quality of integrated school-based 
and work-based learning and instruction, assess learner performance, 
and certify proficiency. The notice refers to standards developed 
under Goals 2000 as an example of such State-developed and validated 
measures. In response to the comment that Goals 2000, and, by 
association, this notice, disregards significant work already 
undertaken through the Perkins Act, the Departments would point out 
that under Goals 2000, participating States must coordinate their 
improvement plans both with any School-to-Work efforts and with 
strategies to integrate academic and vocational instruction as 
outlined in the Perkins Act. (See Goals 2000, section 306(j) and 
(1).) The School-to-Work Opportunities Act defines the integrated 
work-based and school-based components as incorporating, to the 
extent possible, all aspects of the industry, and providing 
academic, vocational, technical and production skills as well as 
general workplace competencies (see sections 4(1), 101 and 102 of 
the Act). Whether education reform and standards development occur 
independent from, or in relation to, the Goals 2000 initiative, it 
is important that the School-to-Work Opportunities plan unfold in 
the context of a systematic vision for improving education in the 
State.
    Changes: None.
Need To Include Sections of the Act in the Notice

    Comment: One commenter believed that the criteria should more 
exactly reiterate definitions and key components contained in the 
Act in section 4 (``Definitions'') and Title I, sections 101-104 
(``General Program Requirements'' and basic program components), 
with specific points assigned for elements such a those described in 
section 213 (d) (``State Plan'') of the Act. The commenter also 
suggested that the Departments restore language, included in the Act 
but omitted from the final bullet of Criterion 1 B, linking career 
majors to the assessment and certification of skills. In the opinion 
of the commenter, the exclusion of this reference from the criterion 
altered the meaning of this section.
    Discussion: While the Departments concur with the commenter on 
the importance of these provisions, they do not believe it is 
necessary to restate in the notice most of the legislative language 
emphasized by the commenter, or that it is necessary to assign 
points for every statutory requirement. The notice advises States 
that applications must meet all the requirements of the Act, 
reiterates that all definitions in the Act apply to systems funded 
under the State Implementation Grant competitions, and emphasizes, 
under Criterion 1, the need for State plans to demonstrate 
consistency with all statutory requirements and with all system 
components in Title I of the Act. Therefore, the Departments 
strongly encourage applicants to refer to the Act as well as the 
criteria in developing School-to-Work Opportunities plans which 
reflect the full intent of the law. The Departments wish to assure 
the commenter that panelists reviewing the applications are selected 
for their understanding of the School-to-Work Opportunities Act, are 
required to participate in a carefully designed orientation, and 
must score applications based on the criteria, in conjunction with 
the requirements of the Act. The Departments agree with the 
commenter that the bullet relating to assessment and certification 
of skills would be strengthened and clarified by including a 
reference to career majors, as given in section 213(d)(16) of the 
Act.
    Changes: The final bullet in Criterion 1 B now includes the 
language of section 213(d)(16) of the Act regarding the State's 
process for assessing skills and knowledge required in career 
majors.

Distribution of Points

    Comment: One commenter questioned the distribution of points in 
this section, and believed that Criterion 1 B, under Comprehensive 
Statewide System, should receive more weight than 15 out of 100 
points. Another commenter recommended that the points assigned to 
Criterion 3, ``Participation of All Students,'' be increased from 15 
to 20.
    Discussion: In response to this comment, the Departments gave 
careful consideration to the distribution of points among the 
selection criteria, and have concluded that the distribution 
provided for in the notice results in the most appropriate balance 
among the criteria.
    Changes: None.

Supported Work

    Comment: One commenter recommended adding supported work 
activities or experiences to several criteria to highlight what can 
be done at the work site to assist students with disabilities.
    Discussion: The Departments agree that supported work 
activities, that provide individualized support to assist persons 
with severe disabilities in becoming equal participants in the 
competitive labor force, can be appropriate elements of the work-
based learning component.
    Changes: in Criterion 1 B, the phrase ``supported work 
activities'' has been added to the list of learning experiences that 
may be included in work-based learning. In addition, in Criterion 2, 
the term ``supported work experiences'' has been added to the list 
of opportunities for employers' participation.

Selection Criterion 2: Commitment of Employers and Other Interested 
Parties

Key Stakeholders

    Comment: Many commenters were concerned that by not specifically 
referencing organized labor as a party that should be actively 
involved in the development of the State system, as employers and 
State legislators are referenced, labor's contribution to the 
School-to-Work Opportunities initiative would be diminished. Various 
commenters also indicated that teachers, vocational rehabilitation 
agencies, JTPA service providers, community-based organizations, 
private non-profits, parents, and/or consumers should be explicitly 
identified as key stakeholders in the State system since the 
inclusion of these entities is as vital to the development of the 
system as that of employers.
    Discussion: While the proposed criterion referenced section 
213(d)(5) of the Act, which, in turn, explicitly lists the parties 
the State may involve in the creation of a statewide School-to-Work 
Opportunities system, the Departments agree that it would be helpful 
to identify expressly in the first bullet of Criterion 2 all of the 
parties referred to in section 213(d)(5). In this way, the criterion 
does not appear to exclude any of the entities that have significant 
contributions to make to the establishment of a comprehensive 
School-to-Work Opportunities system. Although the Departments 
believe that labor organizations have unique contributions to make 
to the design and implementation of School-to-Work Opportunities 
systems, Criterion 2 retains State flexibility to determine the 
involvement of specific interested parties listed in section 
213(d)(5) of the Act. The Departments concur with the rationale 
expressed by several commenters that developing high-quality work-
based learning experience requires the commitment of front-line 
workers as well as top-level managers and CEOs. Applicants are 
encouraged to utilize labor organizations and other key parties 
toward this aim.
    Changes: Selection Criterion 2 has been changed to recognize all 
the entities listed in section 213(d)(5) of the Act.

Involvement of Teachers

    Comment: One commenter believed that the involvement of teachers 
should be augmented beyond being listed among ``other interested 
parties.'' This commenter recommended that teachers be designated as 
required sponsors of any grant application. This commenter, as well 
as one other, believed that applicants that articulate 
[[Page 26818]] convincing strategies to ensure effective and 
sustained teacher involvement at both the State and local levels 
should receive additional points.
    Discussion: The Departments strongly encourage State teams to 
involve teachers at every stage of system development and 
implementation. A School-to-Work Opportunities system that does not 
effectively incorporate the needs, beliefs, and capabilities of 
classroom educators will not be able to reach the comprehensiveness 
required of system implementation. Additionally, strategies for 
building upon the current practices within a State will not be 
realistic or complete without the input of teachers. Although the 
Departments believe that teachers have unique contributions to make 
to the design and implementation of School-to-Work Opportunities 
systems, Criterion 2 retains State flexibility to determine the 
involvement of specific interested parties listed in section 
213(d)(5) of the Act. Also, consistent with section 213(b)(4) of the 
Act, the Departments do not believe it is appropriate to mandate 
teacher sponsorship of the grant application. Finally, it is 
noteworthy that the importance of teachers' participation in School-
to-Work Opportunities systems is further conveyed by the specific 
reference to teachers within the definition of ``local 
partnership,'' in section 4(11)(A) of the Act. That section provides 
that local partnerships must include, among others, ``local 
educators (such as teachers, counselors, or administrators) * * *''
    Changes: As stated above, Criterion 2 now includes reference to 
each entity listed in section 213(d)(5) of the Act. Selection 
Criterion 4 has been changed to add, as its first bullet, the 
ability of the State to ensure that local partnerships include all 
of the entities listed in section 4(11)(A) of the Act.

Consultation With Organized Labor

    Comment: Several commenters supported the addition of a 
requirement that the State directly consult with the State AFL-CIO 
in order to coordinate organized labor involvement at both the State 
and local levels. Many commenters supported this concept by 
requesting that the Departments require States to define a 
particular role for organized labor, tie this requirement to 
Criterion 2, and assign points to the requirement. Lastly, one 
commenter believed that it would be appropriate to include a special 
note requesting that States develop distinctive strategies to 
utilize organized labor.
    Discussion: The Departments agree that organized labor is a key 
contributor to the development and implementation of comprehensive 
School-to-Work Opportunities systems. As many commenters suggested, 
labor organizations have significant contributions to make in a 
variety of aspects of such systems--from designating workplace 
mentors and helping to ensure safe work environments to the 
establishment of realistic skill standards. The Act thoroughly 
delineates who must collaborate in the development of a statewide 
system, as stated in section 213(b)(4) of the Act, which includes 
representatives of the private sector, as well as the other 
interested parties who are encouraged to be involved, as stated in 
section 213(d)(5) of the Act which includes ``labor organizations or 
associations of such organizations.'' The Departments do not believe 
that it is appropriate to mandate additional requirements beyond 
those contained in the Act or to define a role for any stakeholder 
group; however, strong applications will be those that represent the 
greatest amount of collaboration among stakeholders. Applicants are 
reminded that labor organizations or nonmanagerial employee 
representatives are required members of local partnerships in the 
School-to-Work Opportunities system, and, in response to another 
comment, Criterion 4 now identifies all required members of local 
partnerships.
    Changes: None.
Bureau of Apprenticeship and Training Involvement

    Comment: One commenter suggested that States designate a Federal 
Bureau of Apprenticeship and Training (BAT) representative as a 
State partner in order to avoid any duplication of effort between 
established apprenticeship programs and School-to-Work activities 
being developed as a result of the Act. The commenter referenced the 
Act's specificity with regard to non-duplication of effort.
    Discussion: Section 213(d)(5) of the Act, referenced in 
Criterion 2, includes registered apprenticeship agencies as entities 
that States may actively and continually involve in the development 
and implementation of statewide systems. The term ``registered 
apprenticeship agency'' is defined under section 4(13) of the Act to 
mean ``the Bureau of Apprenticeship and Training in the Department 
of Labor or a State apprenticeship agency recognized and approved by 
the Bureau of Apprenticeship and Training as the appropriate body 
for State registration or approval of local apprenticeship programs 
and agreements for Federal purposes.'' Since Criterion 2 has been 
changed to identify all entities listed in section 213(d)(5) of the 
Act, and since the Act includes the Bureau of Apprenticeship and 
Training in its definition of ``registered apprenticeship agency,'' 
the Departments believe that the criteria adequately allow for the 
inclusion of the Bureau of Apprenticeship and Training in State 
system-building activities.
    Changes: None.

Selection Criterion 3: Participation of All Students

Participation of Target Groups

    Comment: Many commenters suggested ways to emphasize the 
participation of a particular target group or groups included in the 
definition of ``all students.'' Some commenters recommended 
requiring specific strategies or plans for one or more of the target 
groups. Some believed that the ``Note'' on students with 
disabilities and dropouts was helpful, but that the concept of 
developing strategies for students with disabilities and school 
dropouts would be strengthened if it were added as a separate 
consideration in Criterion 3. One commenter wanted to add a ``Note'' 
reminding applicants of the importance of nontraditional employment 
for women in School-to-Work and asking for identification of 
barriers and methods for overcoming them. One commenter suggested an 
alternative method for addressing the participation of all students. 
The commenter was concerned that assigning 15 points to a criterion 
that included all types of students might permit continuation of 
historical exclusionary practices because applicants could provide 
strong strategies for some students, but not include others and 
still be awarded high marks on this criterion.
    While most of the comments relating to participation of target 
groups recommended requiring specific strategies for a particular 
target group, one commenter did not want to focus on any special 
group. This commenter believed that the strength of the School-to-
Work Opportunities Act is that it is designed for all students, and 
that the system itself is the solution for different groups.
    Recommendations for where in the notice changes should be made 
included Criteria 1, 3 and 4. Although most commenters wanted States 
to be required to provide more specific attention to a particular 
group in Criterion 3, several suggested adding language to the 
fourth bullet in Criterion 1A in order to correct past histories of 
exclusion or to help raise State awareness that the range of options 
should be available to a specific target group or groups. One 
commenter recommended adding language to Criterion 4 that would 
encourage States to help local systems use technology-based 
instructional techniques for students with disabilities. Another 
commenter recommended replacing Criterion 3 with what was referred 
to as a ``threshold criterion.''
    Discussion: Criterion 3 requires a State to describe its 
strategies for effectively ensuring opportunities for all students 
to participate, and to identify ways of overcoming barriers to the 
participation of any students. The additional considerations in this 
criterion for young women and for students from rural communities 
with low population densities reflect the required content of the 
State plan, as described in section 213(d) of the Act. Balancing the 
design of a system that serves all students with the need for 
targeted strategies for some students is one of the most difficult 
aspects of implementing the School-to-Work Opportunities initiative. 
Like the Act, Criterion 3 refrains from requiring applicants to 
design specific programs for each specific group of students. 
Rather, the focus is on building a system for all students. The 
Departments agree that to receive the maximum points on Criterion 3 
applicants must not neglect the needs of any students, and must 
convincingly describe how the State's School-to-Work Opportunities 
system will provide the same options and produce the same results 
for all participating students, while recognizing that groups of 
students have different needs and, therefore, that specific 
strategies may be required for the target groups listed in the 
definition of ``all students.'' Applications that fail to address 
the critical needs of each category of student and fail to develop 
effective strategies based on identified student needs will not be 
as competitive as applications that have 
[[Page 26819]] comprehensive and effective strategies for all 
students. To be competitive, States that have not fully established 
all components of the strategies devised for all students, should 
have at least a timetable for putting all aspects of their 
strategies in place within a reasonable period of time. Finally, the 
Departments do not agree that Criterion 3 should be replaced with a 
threshold criterion or an eligibility requirement or that either of 
these would be consistent with the Act.
    Changes: A reference to the definition of ``all students'' in 
section 4 of the Act has been added to Criterion 3 in order to 
remind applicants of the scope of the term.

Define ``All Students''

    Comments: Several commenters suggested that a definition of the 
term ``all students'' be added in the Definitions section of the 
Notice or that the specific student categories be defined. The 
commenters believed that the notice of final priority and selection 
criteria for the FY 1994 competition was clearer about the 
definition and that the significance of the requirement for ``all 
students'' needed to be emphasized.
    Discussion: The final competition for State Implementation 
Grants in 1994 was announced prior to passage of the School-to-Work 
Opportunities Act. Consequently, it was necessary last year to 
provide more detailed information and definitions in the Notice--
anticipating the School-to-Work Opportunities legislation--while 
ensuring consistency with Cooperative Demonstration authority of the 
Carl D. Perkins Vocational and Applied Technology Education Act, 
under which the FY 1994 State Implementation Grant awards were 
funded. For this second round of competitions, all definitions and 
requirements of the Act apply. However, the Departments agree that 
it would be helpful to remind applicants that the definition of the 
term ``all students'' applies to this competition.
    Changes: A reference to the definition of ``all students'' in 
section 4(2) of the Act has been included in Criterion 3.
Equal Access

    Comment: Two commenters recommended that Criterion 3 be expanded 
to include language requiring equal access to program components for 
all students. One of these commenters also recommended that 
Criterion 3 should require equitable representation of all students 
and equal access at the inception of the grant. The equal access 
language in Title I of the Act was considered by the commenter to be 
the cornerstone to ensuring participation of all students.
    Discussion: Section 101 of the Act defines the general program 
requirements for all School-to-Work Opportunities systems and 
requires that they ``provide students with equal access to the full 
range of such program components (including both school-based and 
work-based learning components) and related activities, such as 
recruitment, enrollment, and placement activities, except that 
nothing in the Act shall be construed to provide any individual with 
an entitlement to services under this Act.'' As noted elsewhere in 
this Appendix, applicants were reminded in the notice of proposed 
selection criteria, and will be reminded in the final application 
package, that applications must meet all requirements of the Act. 
However, the Departments agree that the requirement for equal access 
is so central to the purpose of School-to-Work Opportunities, that 
applicants should be reminded that programs must provide equal 
access to the full range of program components to all students.
    In regard to the comment suggesting that equal access be 
required from the inception of the grant, the Departments believe 
that some States may have an effective plan for a comprehensive 
School-to-Work Opportunities system even if all components of their 
plans, including their strategy for ensuring equal access to the 
full range of School-to-Work Opportunities program components, would 
not be fully operational at the beginning of the Implementation 
Grant period. However, in order to be competitive, a State should be 
able to: (1) Demonstrate an effective strategy for assisting all 
students to take advantage of the opportunities to fully participate 
in a School-to-Work Opportunities program that meets the 
requirements of Title I, and (2) describe the timetable for fully 
implementing the strategy.
    Changes: Language from section 101(5) of the Act relating to 
equal access has been added to Criterion 3.

Monitoring

    Comment: Several commenters recommended that State be asked to 
provide specific detail on how they plan to monitor the safe and 
healthy work environments that are required under section 601 of the 
Act. Some of these same commenters believed that joint labor-
management safety committees and the State AFL-CIO should be 
consulted in designing the monitoring mechanisms.
    Discussion: Under Criterion 3, reviewers will consider the 
State's methods for ensuring safe and healthy work environments for 
students. Many activities may be a part of a State's strategy for 
ensuring that students are provided safe and healthy work 
environments, including risk assessment, assignment of 
responsibility for safety, and monitoring. However, although the 
Departments do not believe it is appropriate for them to define the 
components of the strategy that all States must use to ensure safe 
and healthy work environments, the bullet has been modified to 
clarify that State strategies should include both school-based and 
work-based components.
    Furthermore, while the Departments agree that labor-management 
safety committees would be in an excellent position to provide 
assistance in designing monitoring mechanisms, the School-to-Work 
Opportunities Act provides States with flexibility to develop and 
implement School-to-Work Opportunities systems that best fit the 
needs of the State, while meeting the requirements of the Act. Who 
is involved in designing pieces of the State's system will be 
determined by the State and local partners.
    Changes: The final bullet of Criterion 3 has been modified to 
encourage safety training to be included in both the school-based 
and work-based components.
Work Environment Free From Harassment
    Comment: One commenter recommended that States be required to 
explain how they will ensure that student work environments are free 
from racial and sexual harassment.
    Discussion: The Departments agree that providing environments 
for students that are free from racial and sexual harassment is an 
important aspect of School-to-Work. Section 213(d)(14) of the Act 
directs States to describe the State's goals and methods for 
addressing the issues of participation in School-to-Work programs by 
young women. That section also requires States to describe their 
``goals to ensure an environment free from racial and sexual 
harassment.'' The purpose of publishing the ``Notice of proposed 
selection criteria'' was to provide an opportunity for comment on 
the criteria that reviewers would use in evaluating applications; it 
was not to repeat the entire contents of the State plans, as defined 
in section 213(d). However, the Departments agree with the commenter 
on the importance of the efforts of States and local partnerships to 
ensure that students are provided with work environments, free from 
racial and sexual harassment.
    Changes: The phrase from section 213(d)(14) of the Act, ``and 
has developed realistic goals to ensure an environment free from 
racial and sexual harassment,'' has been added to the third bullet 
under Criterion 3.
Focus on Communities With High Concentrations of Poor and 
Disadvantaged Youth

    Comment: One commenter suggested that the section that deals 
with the State's strategy for serving students from rural 
communities with low population densities include a specific 
reference to communities with high concentrations of poor and 
disadvantaged youth.
    Discussion: Since Criterion 3 considers the extent to which the 
School-to-Work Opportunities system is designed to reach all 
students, the Departments believe the notice adequately addresses 
the inclusion of such communities in the State's plan for 
implementing systemic change across all geographic areas of the 
State. Disadvantaged students are specifically noted in the Act's 
definition of ``all students.'' (See section 4(2).) Applications 
that do not outline convincing strategies for including all students 
in the School-to-Work Opportunities system will be less competitive 
than those that do.
    Changes: None.

Alternative Assessments

    Comment: Several commenters noted the importance of providing 
flexibility in assessment processes. Some of these commenters 
suggested adding considerations to Criterion 3 that encourage the 
development of alternative assessment techniques and alternative 
methods of meeting skill benchmarks that do not penalize students 
for a deficit related to the assessment technique being utilized.
    Discussion: The Act provides flexibility for States to design 
School-to-Work Opportunities systems that respond to the unique 
needs and opportunities of each [[Page 26820]] State. The State plan 
that is part of the application for a State Implementation grant 
must include a description of the State's processes for assessing 
skills and knowledge required in career majors and for awarding 
skill certificates. In addition, under Criterion 3, reviewers will 
assess the extent to which the applicant has identified barriers to 
the participation of any students.
    Changes: None.

Selection Criterion 4: Stimulating and Supporting Local School-to-Work 
Opportunities Systems

Stakeholder Involvement at the Local Level

    Comment: Two commenters suggested that States be asked to 
describe their efforts to involve organized labor at the local 
level, including recommended strategies for local areas to address 
labor market needs and build the capacity of their local 
partnerships by involving labor organizations during the early 
stages of initiative development. An additional commenter asked that 
States be required to ensure that local partnerships include 
students and community-based organizations in the development of 
local School-to-Work Opportunities systems.
    Discussion: Section 4(11)(A) of the Act states that local 
partnerships must include: employers, representatives of local 
educational agencies and local postsecondary educational agencies 
(including representatives of area vocational education schools, 
where applicable), local educators (such as teachers, counselors, or 
administrators), representatives of labor organizations or 
nonmanagerial employee representatives, and students. In addition, 
section 215(c)(2) of the Act lists conducting ``outreach activities 
to promote and support collaboration, in School-to-Work 
Opportunities programs, by businesses, labor organizations, and 
other organizations'' as an activity in which the State may become 
involved in carrying out the statewide School-to-Work Opportunities 
system. Bearing these points in mind, the Departments believe that 
the most competitive State applications will contain strategies for 
local areas that promote high levels of local partnership 
collaboration and that can effectively demonstrate an awareness of a 
local partnership's capability for inclusion of all parties 
necessary for local initiative implementation and correlation to the 
statewide system.
    Changes: Selection Criterion 4 now includes, as its first 
bullet, the ability of the State to ensure that local partnerships 
include all of the entities listed in section 4(11)(A) of the Act.

Staff Development

    Comment: Two commenters requested that staff development be 
included in Criterion 4. One commenter focused on requiring States 
to set aside resources and develop a long-term plan for providing 
staff development activities to all staff members within secondary 
schools. The other commenter indicated that State applications 
should be assessed based upon their efforts to provide training for 
teachers, employers, mentors, counselors, and other staff that 
includes specialized training directed toward preparing women, 
minorities, and individuals with disabilities for jobs in high-
skill, high-wage industries.
    Discussion: The Departments agree with both commenters and 
believe that the most competitive State applications will include 
strategies for providing staff development for all who are involved 
in the provision of School-to-Work activities for youth. Section 
213(d)(7) of the Act expressly requires that States articulate 
strategies for training teachers, employers, mentors, counselors, 
related services personnel, and others, including specialized 
training to prepare staff to effectively support special student 
populations such as women, minorities, and individuals with 
disabilities. Two other sections in the Act, section 104 (with 
regard to the connecting activities component) and section 215(b)(4) 
(with regard to allowable activities under State subgrants), 
underscore the training of teachers, mentors, and others as vital 
components of any School-to-Work Opportunities initiative. Since the 
Act so strongly emphasizes the critical importance of staff 
development in the implementation of statewide systems, and further 
emphasizes the need for staff development at the local level, the 
Departments are adding explicit language that compels reviewers to 
consider the extent to which states have provided for staff 
development for all staff involved in the provision of School-to-
Work activities for youth.
    Changes: Selection Criterion 4 now includes an additional bullet 
that considers the effectiveness of the State's strategy for 
providing staff development to those who are critical to successful 
implementation of School-to-Work Opportunities systems for all 
youth.

Criterion 6: Management Plan

Evaluation

    Comment: Several commenters were concerned that an evaluation 
plan was not specifically required in State applications. The 
commenters indicated that the presence of a concrete plan for 
research and evaluation would help gauge a State's ability to 
measure the success of, and to continuously improve, its School-to-
Work Opportunities system. Several commenters pointed out that the 
resulting information could be used to systematically assess the 
impact of School-to-Work systems, avoid duplication, identify 
issues, challenges and best practices, and provide models for 
replication. One commenter recommended that grantees collect data on 
the number of exiting participants who are gaining employment and/or 
entering and completing post-secondary education or training. One 
commenter stated that performance measures are more than a 
management issue, and should be considered under Criteria 1 and 4.
    Discussion: The Departments believe that States should have the 
flexibility to design evaluations appropriate to State needs and 
goals, but they agree on the importance of a plan that presents how 
a State will collect and analyze information related to the 
performance measures in section 402 of the Act, as well as any other 
factors the State deems necessary. Since the Departments are 
required to conduct an evaluation of all systems funded under the 
Act, information on the impact of School-to-Work will be gathered. 
(See sections 401-404.) The Departments believe that the notice 
sufficiently emphasizes the significance of performance measures. 
However, the Departments agree with the commenters that Criterion 6 
should relate performance measures and data collection methods to a 
systematic evaluation plan. Reviewers will consider first, whether 
such a plan is in place, second, the extent to which it is likely to 
meet State objectives, third, the extent to which it will be used to 
gauge the success of, and continuously improve, the State's School-
to-Work system, and fourth, the extent to which the State's 
evaluation plan is likely to contribute to the review of results 
across all States.
    Changes: Criterion 6 has been changed to add the words 
``evaluation plan'' as the vehicle for including measurable goals, 
and to include in the bullet the ability of the evaluation plan to 
meet State objectives, continuously improve the State system, and 
contribute to the review of results across all States.

Addressing Potential Barriers

    Comment: One commenter proposed involving organized labor to 
address the potential barrier of providing all students with work-
based learning experiences. The commenter believed that the early 
inclusion of ``member employers of organized labor'' would ensure 
full participation of students in the School-to-Work Opportunities 
initiative.
    Discussion: The Departments encourage States to involve 
representatives of organized labor and others in addressing such 
potential barriers as providing all students with work-based 
learning experiences. As stated in reference to Criterion 2, the 
Departments have agreed to identify each of the entities listed in 
section 213(d)(5) of the Act as stakeholders important to the 
implementation of the statewide School-to-Work Opportunities system. 
The Departments encourage the utilization of each of these entities, 
including organized labor, in identifying and addressing potential 
barriers to student participation and view the change to Criterion 2 
as addressing this commenter's concerns as well.
    Changes: None.

Additional Priority Points [1]--Highest Levels of Concurrence
Highest Levels of Concurrence

    Comment: Three commenters made recommendations for change to the 
section of the Notice on additional priority points for Highest 
Levels of Concurrence. One commenter requested that, in addition to 
awarding priority points for concurrence of the State partners, a 
penalty for nonconcurrence should be applied. Another commenter 
believed that five additional priority points for this criterion was 
not appropriate because the basis for assigning the additional 
points was not clear, and it would be difficult for reviewers to 
differentiate between perceived and actual collaboration. Another 
commenter believed that this section should be revised to encourage 
States to utilize staff who are [[Page 26821]] qualified to deliver 
services to special population groups.
    Discussion: In response to the first comment, the Departments 
note that reviewers may add a maximum of 5 points for applications 
that demonstrate that all State partners listed in section 213(b)(4) 
concur with the plan and have committed time and resources to 
implementing it. Applications that do not fully demonstrate such 
concurrence will receive less than 5 points, which is, in effect, a 
penalty for nonconcurrence, as the commenter suggested. Regarding 
the second suggestion, the Departments note that the basis for 
awarding 5 additional points for ``Highest Levels of Concurrence'' 
is adequately described. To assist reviewers in differentiating 
between perceived collaboration and actual collaboration, applicants 
must show how the concurrence of each partner is actualized through 
a commitment of time and resources. Regarding the third suggestion, 
section 214(a) of the Act specifies that priority is to be given for 
concurrence with the State plan by those organizations listed in 
section 213(b)(4) that are required to collaborate in the 
development of the application. This section of the Act is a 
recognition that system-wide change cannot occur unless the State 
officials with the authority and resources for related education and 
training programs fully commit to system-wide change. How 
effectively local School-to-Work Opportunities programs or 
activities are delivered is a consideration in several other 
criteria, including Criteria 3, 4, and 6.
    Changes: None.

Additional Priority Points [2]--Paid, High Quality Work-Based Learning

Difficulty of Rural States in Meeting Priority

    Comment: Several commenters were concerned that this section 
would favor urban, industrialized States over rural non-
industrialized States because the former have greater numbers of 
employers able to provide paid work experiences. While one commenter 
agreed with placing some emphasis on paid, high-quality work-based 
learning, most of these commenters pointed out that rural States 
have limited access to employers due to factors such as geographic 
isolation, predominance of small businesses, and a smaller base of 
non-hazardous industry. Two commenters noted that the Act describes 
paid work experience as a preferred, but not mandatory, activity of 
School-to-Work Opportunities systems, indicating that a ten-point 
priority for this factor exceeds the intent of the law. Other 
commenters noted that many rural School-to-Work Opportunities 
systems will rely mainly on school-sponsored enterprises, school-
based simulations and unpaid work-based learning, and that students 
also benefit from these experiences. One commenter suggested that 
more information be provided in this section on what constitutes 
high-quality work-based learning. One commenter suggested that 
points be reduced under this section, and additional points be 
awarded for rural School-to-Work strategies under Criterion 3.
    Discussion: The Departments are committed to a fair and 
equitable review of all applications, and recognize that, in order 
to be successful, a School-to-Work Opportunities system must take 
into account the unique needs and conditions of the State by which 
it has been designed. The Departments agree that unpaid work 
experiences and alternatives such as school-sponsored enterprises 
are highly valuable in providing students with the opportunity to 
gain and apply skills. This priority does not require paid work 
experience for every student, but emphasizes paid work experience in 
the work-based learning component, and rewards applications which 
demonstrate innovative strategies and high levels of effort in this 
area. The Departments wish to clarify that this section will not 
place rural States at a disadvantage, since points awarded will 
reflect comprehensiveness in developing the work-based learning 
component and attempting to maximize paid work experiences, rather 
than the relative number of students involved in paid work 
experiences. Reviewers rank each State's application against the 
criteria, not against other applications. In assigning points under 
this priority, reviewers will consider the quality of an individual 
State's plan given what is feasible for that State, as described in 
the application. Therefore, the extent to which an application 
presents what is possible and appropriate for the State, as well as 
the State's level of effort in obtaining paid work experiences and/
or designing high-quality alternatives which are accessible 
systemwide, will determine the number of points awarded. Rural 
States that present this information thoroughly and convincingly may 
score higher in this section than urban States that do not 
demonstrate initiative in developing the work-based component.While 
the Departments encourage applicants to review section 103(a) of the 
Act for a definition of high-quality work-based learning, they do 
not believe this definition needs to be restated in the priority.
    Changes: None.

Invitation to Comment

30 Day Submission

    Comment: Several commenters opposed the Departments' decision to 
require States to submit their applications within 30 days of the 
publication of the notice of final selection criteria. Generally, 
these commenters believed that 60 days, rather than the proposed 30 
days, would allow enough time for States to involve and obtain 
support from all of the necessary stakeholders in the submission of 
the State application. Three commenters added that the proposed 
submission time prevents full consultation with regional or local 
stakeholders located throughout the State (particularly large 
States). Commenters further noted that the proposed 30 day submittal 
deadline limits the ability of State educational agencies and others 
who may have dissenting comments to provide them, disregards the 
fact that May is a difficult time to obtain comments from classroom 
teachers, and would nonetheless be unsuccessful in granting awards 
prior to the beginning of the 1995 school year.
    Discussion: While the Departments understand the requests by 
some States for additional time to submit their applications, they 
strongly maintain that, as stated in the notice of proposed 
criteria, the 30 day submittal time is sufficient for States that 
are prepared for comprehensive system implementation. Furthermore, 
the involvement of necessary stakeholders in the endorsement of the 
State application's key components should either already be 
established or be well underway and would not likely be increased 
with the addition of 30 days. Lastly, the establishment of the 
Departments' State Planning Guide for a Comprehensive System, 
distributed shortly after the publication of the proposed criteria, 
provided States with an opportunity to evaluate their current 
progress and assess the status of all system components.
    Changes: None.

[FR Doc. 95-12332 Filed 5-17-95; 2:50 pm]
BILLING CODE 4510-30-M