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DIRECTIVE: OLDER WORKER BULLETIN 98-12

TO: ALL SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM (SCSEP) SPONSORS

SUBJECT: Explanation of the 500-Hour Training Limitation

1. Purpose: To provide guidance to SCSEP sponsors on the 500-hour training limitation.

2. References: 20 CFR Part 641, Senior Community Service Employment Program Regulations.

3. Background: The regulations provide that, generally, enrollees may be engaged in paid participation in training for up to 500 hours. The pertinent regulations read as follows, at 20 CFR Section 641.313 (b):

"Training shall consist of up to 500 hours per grant year and shall be consistent with the enrollee's IDP. Such training may cover all aspects of training; e.g., skill, job search, etc. . . . Waivers for additional hours of training will be considered on an exception basis."

4. Policy on Training: This requirement is meant to apply generally; the Department will be generous in granting waivers, and the provision (500-hour limit) is not intended to discourage training. Further, the regulatory provision does permit more than 500 hours of training, so long as it is arranged without payment to the enrollee for hours of participation in excess of 500 hours (e.g., community college, night school, attendance during non-standard work hours). Waiver requests may be submitted should it be necessary to pay an enrollee for more than 500 hours in a 12-month period. Where feasible, the costs of the training itself should be borne by other resources such as the Job Training Partnership Act and the Carl D. Perkins Vocational and Applied Technology Act.

With regard to in-service training provided to "regular" employees and supervision which is provided at the host agency to enrollees, it is expected that enrollees would be included in such in-service training and that such participation would not count against the 500-hour limitation.

Under Section 502(e) of the Older Americans Act (OAA), projects may enter into on-the-job training (OJT) agreements with employers in the private sector. For such OJT agreements, there is no limit on the length of training. Also, all of the costs of OJT may be charged to the enrollee wages and fringe benefits cost category.

Further, the 500-hour training limitation is not applicable to the experimental projects authorized under Section 502(e) of the OAA. Longer periods of training time may be provided without limitations or the need for waivers.

5. Tracking Compliance: With regard to tracking compliance with the 500-hour limitation, the same options are available to sponsors as were discussed in Older Worker Bulletin No. 98-13.

(a) A "running" 12-month period that changes day-to-day, so that the 500 hour limitation would involve a "look-back" for each individual from the date of examination of the enrolled files;

(b) The 12-month grant year (program year) period;

(c) The 12-month period from enrollees' anniversary dates;

(d) The 12-month calendar year; or

(e) Any other 12-month period (e.g., fiscal year).

Sponsors should identify the designated 12-month period for tracking compliance in the grant agreement.

6. Inquiries: Questions may be directed to the appropriate Federal Representative on (202) 219-5904.

ATTACHMENT: None

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