26812 Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices

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.

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 highskill, 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 Schoolto-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-toWork 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 schoolage 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
Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices 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:

• Overall system management, system

coordination, and general

administrative functions;

• Preparing program plans, budgets,

and schedules, as well as applicable

amendments;

• Monitoring of local initiatives, pilot

projects, subrecipients, and related

systems and processes;

• Procurement activities, including

the award of specific subgrants,

contracts, and purchase orders;

• Developing systems and

procedures, including management

information systems, for assuring

compliance with the requirements

under the Act;

• Preparing reports and other

documents related to the Act; and

• 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—

• Includes effective strategies for

integrating school-based and workbased learning, integrating academic

and vocational education, and

establishing linkages between secondary

and postsecondary education;

• 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.

• 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;

• Ensures that all students will have

a range of options, including options for

higher education, additional training

and employment in high-skill, highwage jobs; and

• 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-toWork 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—

• 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, jobshadowing, unpaid work experiences,

school-sponsored enterprises, supported

work experiences, and paid work

experiences;

• 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:

• A connecting activities component

to provide a functional link between

students’ school and work activities and

employers and educators; and

• 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:

• 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.

• 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.

• 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-toWork Opportunities system.
26814 Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices

• 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, jobshadowing, 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:

• 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.

• 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.

• 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.

• The feasibility and effectiveness of

the State’s strategy for serving students

from rural communities with low

population densities.

• 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 Schoolto-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:

• 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).

• The extent to which the State

assists local entities to form and sustain

effective local partnerships serving

communities in all parts of the State.

• Whether the plan includes an

effective strategy for addressing the

specific labor market needs of localities

that will be implementing School-toWork Opportunities systems.

• 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.

• 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 technologybased instructional techniques.

• 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.

• 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:

• 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.

• 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.

• 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:

• The adequacy of the management

structure that the State proposes for the

School-to-Work Opportunities system.

• The extent to which the State’s

management plan anticipates barriers to

implementation and proposes effective

methods for addressing barriers as they

arise.

• 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.

• 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.

• Whether the plan includes a

feasible workplan for the School-toWork Opportunities system that
Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices 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—

• 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—

• 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, highquality work experiences to the largest

number of participating students as is

feasible; and

• Has established methods for

ensuring consistently high quality workbased 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-toWork 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, highquality 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-toWork 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-toWork 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 Schoolto-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
26816 Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices

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, Schoolto-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 fouryear 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 Schoolto-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 lifelong 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 nowrevised 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 workbased 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
Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices 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-toWork and Goals 2000 are coordinated and

mutually reinforcing. A major focus of

Criterion 1 is the need to integrate School-toWork 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 Statedeveloped 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-toWork 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-toWork 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 workbased 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-toWork 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 frontline 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
26818 Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices

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 Schoolto-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 systembuilding 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-toWork 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
Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices 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-toWork 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 Schoolto-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
26820 Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices

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 longterm 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 highskill, 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-toWork 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 postsecondary 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 workbased 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-toWork 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
Federal Register / Vol. 60, No. 96 / Thursday, May 18, 1995 / Notices 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 nonindustrialized 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-toWork Opportunities systems will rely mainly

on school-sponsored enterprises, schoolbased 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 schoolsponsored 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 highquality 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