DATE: August 31, 1998
DIRECTIVE: OLDER WORKER BULLETIN 98-31
TO: ALL SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM (SCSEP) SPONSORS
SUBJECT: RECERTIFICATION OF ELIGIBILITY OF SCSEP PARTICIPANTS
1. Purpose: To provide policy interpretation on the regulatory requirement to recertify each SCSEP enrollee once each project year.
2. References: Title V of the Older Americans Act (OAA), as amended, P.L 100-175, P.L. 102-325, the Final Rule, and Older Worker Bulletin 96-5.
3. Background: 20 CFR Part 641.305(e)(1) states that: "Each grantee or subgrantee shall recertify the income of each enrollee under its grant or subgrant, respectively, once each project year, according to the schedule set forth in the grant agreement and shall maintain documentation to support the recertification." To comply with the regulatory requirement, some SCSEP sponsors have implemented procedures that require significant expenditures of staff time and resources. This bulletin provides guidance to alleviate this problem.
4. Policy: Recertification should not be an onerous workload requirement. Therefore, through this bulletin, we are providing a policy interpretation to help sponsors develop procedures that will simplify the process.
5. Action: It is our hope that sponsors will reassess their procedures with an eye to the elimination of duplicative or otherwise overly burdensome recertification procedures. For instance, sponsors may develop and implement recertification procedures that remind enrollees each project year to provide notification of significant changes in income or family size that may effect eligibility. A note placed in the file or some other appropriate evidence would be sufficient to demonstrate that the sponsor reminded the enrollee. If the enrollee provides no information, then it may be assumed that there has been no significant change in income.
If notification of changes is received, information shall be reviewed by sponsors and documented appropriately. If an enrollee is then determined to be ineligible, the sponsor shall send a written notice of termination to the enrollee, and the enrollee shall be terminated 30 days after the notice. Further, if at anytime the project staff suspects that an enrollee is over the SCSEP income level, they may ask the enrollee to provide information for the necessary eligibility documentation.
Any grant modifications required by these changes should be forwarded to your Federal Representative in the form of a memorandum that will be attached to the current approved grant.
6. Effective Date: Date of this bulletin.
7. Inquiries: Questions should be directed to your Federal Representative at (202) 219-5904.