Box 3, Folder 17, Document 93

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Box 3, Folder 17, Document 93

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WASHINGTON, D.C, 20210 ! yor’
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“October 9, 1968 [Df °°" -- ME


Subject: Implementation of Title I-B of the 1967 EOA Amendments

1. -Purpose. To delegate authority and assign responsibility for the
aduinistration of work and training programs under Section 123 of Title
I-B of the Economic Opportunity Act of 1963, as amended (EOA). Excluded
from consideration herein is that part of EOA Title I-B programs and
resources devoted to the Job Opportunities in the Business Sector (JOBS)
progran. '

2. Background. The Economic dpportuahey Act Amendments of 1967 i
consolidate authority for all the delegated work and training programs °
now administered by the Manpower Administration under Section 123 of

the EOA. The law now requires that: |

(a) a community program area (CPA) be designated for the purpose
fc ae and conducting comprehensive work and training programs

(b) all work and training components be consolidated into a CWIP
and financial assistance for such programs provided through a
prine sponsor (PS) after July 1, 1968, and : %
(c) the Federal-Staté employment service provide and develop

further its capacity for providing maximum support for manpower
training programs.

The implementing instructions set forth herein are provided to insure

that each comprehensive work and training program (CWIP) will provide

an unbroken sequence of useful training and work opportunities together

with appropriate remedial and supportive services to target groups of
unemployed and low income persons so that they can obtain and hold

regular competitive jobs. The goal is a comprehensive delivery system ‘ :
which marshalls the total manpower resources available to overcome

the complex employment problems of the most severely disadvantaged in

the rural and urban areas in which they are concentrated. The =
instructions outline a systematic approach to planning and implement-~

ing the CWTP which takes into consideration the need to provide local

leaders and mambers of the groups to be served, with the opportunity
tovparticipate in the decisions which aetermine how manpower resources

“are to be allocated and utilized.:


\ | * OCT 25 808

3. Delegation of Authority and Assignment of Responsibility.

A. The Regional Manpower Administrators (RMAs) and the Manpower Admini-
strator for the District of Columbia are hereby delegated authority and
assigned responsibility in respect to those functions and programs
authorized by Sections 121, 122, and 123 of the EOA, as.amended,


(1) designating commnity program areas (CPA), for the purpose
of planning and conducting comprehensive work and training ,
programs (CTP),

(2) recognizing a prime sponsor (PS) to receive all financial
assistance for prograus under section 123 and to plan and conduct
comprehensive work and training programs (CWTP), 1S

(3) approving a comprehensive work and training proprem (cwrP)
for each community program erea (CPA), which shall cousolidate
all work and training components commencing July i, 1968,

. (4) approving and executing all contracts and agreements for |
By ee programs and projects to implement an approved comprehensive “
work and training program (CTP);

(5) assuring that the Federal-State employment service provides
and develops its capacity for providing maximum support for such
manpower programs, ,
B. All authority delegated and responsibility assigned to the
Regional Manpower Administrators and the Manpower Administrator for
the District of Columbia by this Order shall be exercised according
to the implementing instructions contained herein and subsequent
guidelines and standards issued by the Manpower Administration,
It should be noted that the instructions require the RMA, in
specified instances, to odtain the concurrence of the OFO field
staff before a final action is taken.


4, ‘Approved Policies. In accordance with the terms of the agree-

- ment reached between the Office of Economic Opportunity (OE0) and
the Department of Labor (DOL) embodied in the Memorandum of Agreement
dated April 12, 1968, the policies set forth below have been jointly
developed and approved by CEO and DOL,

A. Consultation with Local Government Officials

, 1
The ‘an tit, in the course of his initial planning for the
establishment of a comprehensive work and training program in
& comunity, consult with the head(s) of local govermaent(s).
Consultation is also required prior to his making major progran
determinations affecting an ongoing CWIP.

‘1/References throughout this Order to RMA include the Manpower Admini=
strator for the District of Columbia.

B. Designation of a Prime Sponsor (PS)

APS isa public or private nonprofit a eney which is capable of
(1) receiving and disbursing funds and (2) planning, develomlag,
administering, coordinating and evaluating a CWTP.

(1) The CAA in a community is the PS of a CWIP and shall be
_ chosen unless it is jointly determined by OEO and DOL to be

incapable of performing the functions of a PS and cannot be
‘feasibly provided with that capacity. Within 30 days after
..designation of a CPA, the RMA will solicit in writing, and

accept an application for REEOEOA SLC: as PS from the local

Once the RMA has tentatively selected a PS, he will immediately
notify in writing, the OEO Regional Office and the appropriate
CAMPS committee. When exception is taken by OEO to the non-~
selection of an existing CAA, the checkpoint procedure jointly
developed by OEO and DOL will be followed (see paragraph 4H

(2) Where OEO and DOL agree that an existing local CAA will
not be the PS, or where there is no CAA in existence, the RMA will
promptly solicit and accept applications for sponsorship from
non=-CAA agencies. In such situations, the State employment
service or other agencies of State goverment, local governmental
jurisdictions, or private non-profit agencies may be designated
as Prime Sponsors wherever they qualify.

\When an application for sponsorship has been submitted to
the RMA by an agency other than a CAA, the RMA will furnish
two copies thereof to the appropriate CAMPS committee.
Within 10 days of receipt of all non-CAA applications for
sponsorship, the CAMPS coumittee will schedule interviews with
each applicant and forward its recommendations on the merits
of each claim for sponsorship to the RMA for his final
.decision, The relevant CAMPS committees will be notified
of all selections: of PS's by the RMA.


(3) The PS is responsible for assuring that delegate agencies
satisfactorily perform their responsibilities, including
providing for participation and employment of members of .
groups served. When, in the course of monitoring the performance
of delegate agencies, the PS finds unsatisfactory performance, —
he shall seek immediate corrective action by the delegate

agency, appealing to higher organizational levels of the

agency, aa necessary. If the delegate agency remains un-
responsive, the PS shall seek corrective action through

the .RMA, and ultimately, through appeal to the Manpower

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(4) The RMA shall review annually the performance of each
PS, applying the standards of project effectiveness developed
end published as described in Section .132(c) of ‘the EQA,

(5) All financial assistance for a CYTP in a CPA must be °-. . |
provided through a PS, unless a determination has been made .
by the RMA that:

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(a) there is a-good cause for an extension of time Or, :
; \

(b) after soliciting and considering the ccxzments of the

PS, if any, it is determined that the provision of financial

assistance to a pudlic agency or private organization other

then the PS, for one or more component programs, would :

enhance program effectiveness or acceptance on the part

of the persons served and that such action would serve

the purposes of Title I-B; »

(c) .the project is an in-school Neighborhood Youth Corps ’
(wc) project in which case financial assistance may be
provided directly to local or State education agencies. ; $

When the RMA decides under 5a or b above, to provide financial ~ oo
assistance directly to a public or private non-profit agency Ase
in any community where the CAA is designated as the PS, he will cua”
inmediately notify the O50 Region Office in writing. Where
exception is taken by O£0 to the proposed direct funding by the
RMA under 5a or b above, steps two and three of the OEO=DOL

- checkpoint procedure will be follcwed,

C. Designation of a Community Program Area (CPA) o
A community program area (CPA) is the area for which-a comprehensive

work and training program (CVTP) is planned and within which it is
administered by a prime sponsor (PS). -A neighborhood, city or

multi-city unit, county or multi-county unit, Indian reservation

or other area, may be designated as a CPA if it provides a suitable
organizational base and possesses the Seeaou ety of interest

-needed for the CWTP.

Where feasible, a CPA should be at least city-wide in dimension. 3
However, an erea in which a CEP is already located will be part of ~ .

a CPA or if no broader area possesses the above prerequisites, the .

CEP area itself shall be a CPA.

(1) Designation or recognition of a CPA is to facilitate the
planning and administration of a CWIP for that community.
Areas should be selected upon the basis of such criteria as

the eerent to which:

= 5 =

(a) A suitable organizational base exists in the area;

i (b) a commonality of interest is found smong the various
populations of the ‘Brees ; é
(c) the seléction serves the interests of making broad
comunitywide manpower planning more generally applicable
and expedites the process of planning a CWwTP to meet the
needs of the area; as :

(ad) the pourdansee of the CPA will be consistent with
boundaries of other areas used for the planning of manpower
programs, such:!as Comunity Action Agency (CAA) boundaries, .
local governmental jurisdictions, CEP areas, Model Cities
areas, Standard Metropolitan Statistical Area (SMSA) or CAMPS.

(e) the selection contributes to sound administration of

(2) To help him in selecting areas meeting the above criteria,
the RMA, as chairman of the Regional CAMPS committee, will -
solicit the recommendation of the State CAMPS committee or
when appropriate, the areas CAMPS committee. The CAMPS
recommendation should be solicited in time to aid the RMA
in designating CPAs prior to the date established for the
initiation of the annual et planning cycle.

Before making a final Jasipnatten of a CPA, the RMA will
inform the O£O Regional Office in writing of his proposed
designation. When exception is taken by OEO to the
proposed designation of the CPA, thé checkpoint procedure
Jointly developed by OEO and DOL will be followed. (See ‘
paragraph 4H below). 2

Once a CPA has been designated, the RMA will immediately

notify the OEO Regional office, and the appropr date CAMPS


D. Comprehensive Work and Training Program (CTP)

A CWIP plan, developed through a systematic approach to planning
and implementation, will link all relevant ccmponent programs under
Title I-B with other appropriate public and private manpover
programs and activities so that disadvantaged residents (See
Manpower Administration Order No, 2-68 for definition of the term
"disadvanteged") of a CPA who are enrolled in a CiWTP are provided
with an unbroken sequence of services which will enable them to
obtain and hold employment. The CWIP will contain an analysis

of the needs and priorities of the CPA, together with a complete

@ statement describing how the Title I-B program eccaponents for

which the’ PS has contractual responsibility are to be linked with

. other related manpower programs available in the CPA.


. .(1) Development of a Comprehensive Work and Training Program (CWTP)

The appropriate CAMPS committee annually initiates the planning
eycle for its Comprehensive Manpower Plan by relating the
priorities established to each proposal for déploying program
resources, Regular participants in the CAMPS planning process
will now include the PS who is responsible for planning and
administering a CWIP for the CPA,

The PS will provide the appropriate CAMPS committee with a plan
of action describing how the various Title I-B program elements
for which he has contractual responsibility are to be linked
with other manpower programs available in the CPA, indicate

the role to be played by delegate agencies, and specify, to the
extent feasible, the number of persons involved in each program,
both as staff and enrollees, the amount of funds to be obligated,
and the time schedule for implementation of each project.

The analysis and proposed plan of action for FY 1969 will be
developed and submitted as an amendment to the CAMPS plan and
shall be in the form prescribed in ICI 68-4. ;

The analysis and plan of action for a CWTP will be reviewed

by the appropriate CAMPS ccmmittee to determine whether

it is consistent with the CAMPS Comprehensive Manpower Plan.

‘ No alteration may be made in the analysis and plan of action

for a CWIP without the PS's approval. The area committee

shall then forward the analysis and plan of action for a

CWIP (together with its recommendation) through the State

CAMPS committee to the regional committee, as a separate,
identifiable part of the area CAMPS plan. The Regional x
CAMPS committee will, as part of the process of reviewing and
approving a CAMPS Comprehensive Manpower Plan,’make a recommenda-
tion to the RMA concerning the extent to which the analysis

_ and plan of action for a CWIP is consistent with the Comprehensive
Manpower Plan. After considering this recommendation, the RMA
will accept, reject, or modify the CWIP and immediately furnish
copies of whatever plan has been approved to both the PS and

the appropriate CAMPS committee.

The PS will then prepare the interrelated set of specific

project proposals which, when executed, will complete the z
CWIP, These proposals will be forwarded to the RMA for ;
approval and execution of the necessary documents, Prior

-to acting on the proposed agreement(s)-the RMA shall determine
whether the proposed projects are essential to the implementa-~
tion of a CWIP which is consistent with the CAMPS area plan.
\ 7 -

(2) Contracting

“The overell objective is to have all components of a. CWTP

planned, administered, coordinated, and evaluated by a single:

_ PS who will serve as the sole source of funds for the opera~

tion of those Title I-~B projects for which he is contractually

. responsible, Projects will be operated through delegate

agencies wherever feasible, While all elements of a CWTP
are ultimately expected to be consolidated into a single

“contract, initially these elements need not be expressed in

one contract. Rather a CWTP plan is in effect when both the
analysis, plan and interrelated set of project proposals (action)
have been coordinated and approved by the RMA. Specific project
proposals shall take whatever form is required to implement the

(a) Implementation of a CWTP will not require termination of

' on-going contracts, For éxample, ongoing contracts antedating
development of an approved CWTP shall, wherever possible, be
incorporated in the proposed plan for that CWTP. If the

. CWIP is approved as part of the overall CAMPS plan then all
such contracts may proceed to completion without modification,
Additional funds should not be obligated under existing
contracts where the PS is not the contractor.

Where modifications are necessary they shall be made,

wherever possible, upon the recommendation of the PS,

to avoid termination bring the contracts into.

line with the CWTP. This can be done over a pericd of

time, with minimum disruption to the action portion of

the CWTP.

(>) Where a required modification is substantial or where

an entirely new component is initiated that is not reflected
‘ in an approved CWTP, it will be necessary to amend the

CAMPS “plan in accordance with CAMPS instructions. Such

amendment shall be made before the modified agreement is

forwarded to.the RMA for approval.

(3) Relationship of CEP to CWIP

All CEPs (including existing CEPs) shall be located within a

_ designated CPA end shall be operated by a PS or a delegate

agency and planned and administered as a part of a CWIP. In
‘other words, an area in which a concentration of manpower

‘ programs is provided (CFP area), shall be an integral part of
the CWIP's total response to the problems of the CPA,

E. Provision of Mannower Services

‘ { ‘
The State Exployment Service (SES) is the supplier of all
manpower services for the CTP pursuant to Section 637 of the
EQA, as amemded. ‘Manpower services provided to a CiTP-by a...
SES will be made available to the extent possible from current
SES resources, The provision of these services will be defined
in a meroramdum of agreement (BYIP Form 32 rev.) between the
SES end the Ps,

Tt is the responsibility of the PS to insure that these manpower
services are provided in accordance with terms of the contractual
agreem2nt or the memorandum of agreement referred to above. If
in the course of carrying out his monitoring and overseeing
responsibilities, the PS determines that the SES is not

supply= ng manpover services in a satisfactory manner, he should
attenps to resolve the matter with, the appropriate representative
of the SzS central office. If the problem cannot be resolved at
the SES central office level, he ‘should present his findings to -
the RE,

When as a result of the above procedure the RMA determines that
a SES is not in compliance with the Secretary's Regulations
requiring the SES to be responsible for supplying the manpower
services specified in the CWIP, the RMA will, in consultation
with the PS, arrange for such services to be supplied by

enother private or public agency. The requirements of Section G
of this document are applicable to any Sern Breyeians such
manpower serwicea.

Whenever manpower services are required for a CWIP which are
Over emi above those normally provided by the ES, -the PS
through contractual arrangement, shall reimburse the ES
State Agency for the provision of these additional services.
Guidelines for reimbursement to the SES will be provided in
‘@ subsequent document,

Although the SES is responsible for providing the full range of
manpover services set forth in the CWIP, it is recognized that
it may be necessary or desirable for the SES to make appropriate
' arrangements with other private or public agencies to preiyee

a particular-manpower service, ©

F. Supportive Services

- 1
In designing a CWIP, the prime sponso? or other sponsoring
agency is responsible for making arrangements for the provision
of other needed services, as appropriate, including:
(1) aay cave :

(2) medical services ane

(3) transportation : ; .
(4) family services es ay ag

(5) Legal services : _* ‘

(6) basic or remedial education where not. provided as part

of manpower services.
Comunity Participation
(1) Participation by Representatives of the Poor

It is the basic, continuing and Tegally binding resvonsibility
of ‘each PS to provide for an effective administrative structure

‘ which ensures that representative members of the groups being
‘served in a CPA have direct access to and participate in
the decision-making process involving planaing, conduct and

evaluation of a CWIP and its program ccaponents.

- (a) Ageneles governed or administered by a board of ‘
which at least one third of the menbers are democratically
selected from the groups to be served, shall meet this

' requirement. In all cases where a prime sponsor is not

_ go structured, it should establish a special board which

includes, as at least one third of the mexbership,
democratically selected representatives of the areas
to be served. Those special boards should be given
responsibility for overseeing the plenning, conduct and
evaluation of the CWTP and its components.

_(b) The governing or special board referred to above
should also serve as the policy level participatory
body for delegate agencies required by Section 122 of
the EOA, through one of the following optional arrange-
ments: ‘

(4) The board should appoint a subcommittee composed
of appropriate representatives of the governing or
special board to serve each delegate agency in an
advisory capacity or,

(ii) the board should establish a "delegate agencies
advisory board" ccnposed of zelected members of the

governing or special board and a reprenentenive from
each delegate agency.

In either situation, members of PS boards who represent
the groups being served will function also as monbers of
component boards in order to provide overall cocrdinatica

” of ‘the component programs.
= TO

-, (2) Znrollee Participation
_ It is the responsibility of the prime sponsor and each delegate
_ agency to establish regular procedures for the meaningful parti-
cipation of project enrollees in the -conduct ongoing evaluation
of CirP programs . ;

Each of the delegate agencies will meet with enrollees on a
monthly basis to ensure continuous participation of the enrollees
in the direction of the programs.» The governing board of the

PS should regularly receive comments, criticisms and suggestions
of the project enrollees.

This can be accomplished by using existing representative groups,
specially creating such groups, or by utilizing other equally
acceptable channels of communication. -

‘(3) Labor and Management Participation

The PS shall provide for participation of employers and of .-

yabor organizations in the planning and conduct of the compre-=
hensive work and training programs, in a manner comparable to

that provided for members of the groups being served.

(4) Training, Technical Assistance and Financial Assistance

The PS and the delegate agencies should provide training and
technical assistance to the resident poor board members and
enrollees which is responsive to their needs. Where financial
problems are a barrier to participation, reimbursement for
transportation or babysitting expenses, etc., and compensation
for services on boards or committees should be provided.

(5) Employment of the Poor

The PS and delegate agencies shall provide maxinua employ-

ment opportunities for resident poor of the CPA, including
elderly unemployed and underemployed, in the conduct of -
component programs. This employment shall include opportunity
for further occupational training and career development, and

“upgrading, with funds made aveilable for this purpose.

H. Of0-DOL Checkpoint Procedure

The following checkpoint procedure will apply when exception
is taken by O£O to the non-selection:of an existing CAA as

PS, the situation where OEO objects to the proposed boundaries
of the CPA or when the RMA proposes to provide financial
assistance directly to an agency other than the PS under B 5a

or b above.

(1) When the RMA takes one of the above actions, he will
notify the O£O Regional Director in writing, of his decision




Pas be

and his reason(s) for taking such action. The OEO Regional
Director will have 10 working days to investigate the
situation and attempt to resolve any differences with the
RMA. : : :*
(2) Where these parties are able to reach agreement, the’
agreement will be reduced to writing and signed.

If no agreement is reached, the OF0 Regional Director will
have five additional days to compile and forward all written
deliberations, to the Director of OE0.*

(3) The Director of OEO yill immediately furnish to the
Manpower Administrator a copy of the record and both parties
will have three working deys to resolve the question, Once
‘resolved, the decision will be reduced to writing, signed,
and transmitted to the appropriate RMA. ;

* The RMA will, of course,’ keep the MA informed of this
development through normal internal channels.
5. Authority and Directives Affected. This Order is issued pursuant
to Secretary's Order Nos. 567, 23-67, and°6-68 and implements Manpower
Administration Order Nos. 4-68 and 5-68, and Executive Order No. 11422,

6. Future Changes. During the third quarter of each fiscal year,
representatives of the Department of Labor (DOL) and of the Office
of Economie Opportunity (00), shall jointly review the provisions
‘of this Order and determine what procedural and policy changes
should be made in order to carry out the delegated Title I-B pro-
grams more effectively. Changes in the policies and procedures
described in this Order shall be made with the joint approval of :
OEO and DOL. re a

7. The Office of Economic Opportunity and the Manpower Administration
have jointly developed and approved the policies set forth ;

in this Order,

8. Effective Date. This Order is effective immediately.



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