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c. 7. Describe the Steps Taken to Avoid Disruptions to Service for Participants to the Greatest Extent Possible, when Positions Are Redistributed, as Provided in 20 Cfr 641.365; when New Census or Other Reliable Data Becomes Available; or when There is Over- Enrollment for Any Other Reason. (20 Cfr 641.325(i), 641.302(b))

Current Narrative:

Older individuals often feel vulnerable during times of change. SCSEP grantees in Alabama will make every effort to avoid participant disruptions by reassuring participants and their host agencies that a change of grantee in a particular area will not affect participants’ SCSEP enrollment. Although the schedule for participants’ receipt of their paychecks may vary somewhat from Grantee to Grantee, the mailing and direct deposit of participant paychecks will continue on a regular, dependable schedule.

Changes in Grantee and/or Grantee Service Area

DOL allocates SCSEP-subsidized community service positions to each county using a formula based on the number of individuals ages 55 and older with incomes at or below 125 percent of the federal poverty level in each county. Participants may need to be transferred to a different Grantee if Grantees agree to trade counties to consolidate their service areas and improve the efficiency of their operations.

National Grantee service areas are changed or realigned by DOL. When there is a change of Grantee or Grantee service area, the state will proactively seek to avoid a disruption in service for participants and host agencies.

Changes in the Number of Positions in a County

Other situations may occur where positions in a county may need to be increased or reduced over time, including these situations:

• Census updates on SCSEP-eligible population in counties, such as occurred in 2012, affect the equitable share, or number of positions allocated to a county; • Grantees seek to improve the equitable balance in counties by shifting enrollments from over-served areas to under-served areas.

Strategies to Avoid Participant Disruption

When there is a change in Grantee and/or Grantee service area, the SCSEP State Coordinator will direct the following actions:

• Host a conference call with the grantees involved to ensure that they develop a transition plan and timetable for: o informing participants and host agencies in advance; o transferring records; o holding orientations for participants and host agencies; o and supporting continuity in administrative and programmatic functions.

When positions need to be shifted from over-served to under-served counties, Grantees will carry out the following actions:

• Use a gradual approach to redistribute the slots via attrition; and • Encourage and work intensively to assist job-ready participants in over-served counties to find unsubsidized employment.

A Transition Plan will be implemented that has proven effective in ensuring minimal disruption to participants, host agencies, and the community. Alabama has experience in exchanging service areas with national sponsors. We have worked through and enjoyed smooth transitions. The process includes Notification of Change, Right of First Refusal, Notification to Participants, Record of Transfer, and Participant Placement.

Primary consideration is given to participants when decisions must be made about re-distribution of program positions. Unsubsidized employment is the optimum method for avoiding disruptions to participants in the program, and this policy is applied to the greatest extent possible.

No participants will be terminated for purposes of moving positions to coincide with any new census data or change in grantees. Instead, increased efforts will be made to assist participants through other local SCSEP sponsors, and to aggressively work with participants to obtain unsubsidized employment.

The state will follow the Department’s recommendation of a “gradual shift that encourages participants in subsidized community service assignments to move into unsubsidized employment to make positions available for eligible individuals in the areas where there has been an increase in the eligible population.”

In addition, ADSS will not transfer positions from one geographic area to another without collaboration between all grantees and approval by the Department of Labor. This collaboration between ADSS and national grantees allows for smooth transitions for SCSEP participants, with minimal disruption of service.