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

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:

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 work-based 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, high-wage 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-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--

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;

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-to-Work Opportunities

system. [[Page 26814]]

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:

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 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:

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-to-Work 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 technology-based 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-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--

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, high-quality work experiences to the largest

number of participating students as is feasible; and

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]

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